pole attachment standards · 2019-10-29 · 08/01/2016 1.0 brian d. bartos initial release...
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CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: i
Revision Date: December 6, 2018
Effective Date: January 1, 2019
CPS ENERGY
POLE ATTACHMENT STANDARDS
Version 4.0
Issued Date: December 6, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: ii
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Stakeholders, Management Approval and Document Control
Internal Stakeholders
Jesse Lopez 11/30/2016
Manager, Pole Attachment Services Date
Joseph (Mike) Denning, PE 11/30/2016
Manager, Utility Coordination Date
Adam R. Marin, PE 11/30/2016
Manager, Overhead Engineering Date
Management Approval
Ricardo Lopez, PE 11/30/2016
Director, Distribution Engineering Date
Richard G. Medina, PE 11/30/2016
Senior Director, T&D Engineering & Planning Date
Gabriel Garcia 11/30/2016
Director, Senior Counsel Date
Final Approval
Paul S. Barham 11/30/2016
Senior Vice-President, Delivery Engineering, Integrated Planning,
Substation & Transmission
Date
CPS Energy
Pole Attachment Standards
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Revision Date: December 06, 2018
Effective Date: January 1, 2019
Document Control
CPS Energy Pole Attachment Standards – Version 4.0 Document Title/Version
12/06/2018 Date of Issue
01/01/2019 Effective Date
Revision History
Effective
Date
Version
Number
Individual
Making Edits
Reason/Comments
08/01/2016 1.0 Brian D. Bartos Initial Release
01/01/2017 2.0 Brian D. Bartos Addition of provisions to incorporate Wireless
Installations, revise One-Touch notification, clarify
language and errata corrections to Version 1.0.
01/01/2018 3.0 Jesse M. Lopez Addition of Banner Attachment provisions, revisions
to Wireless Installations standards, revisions to
Exhibits and general updates.
01/01/2019 4.0 Jesse M. Lopez Revisions to Wireless Installations standards,
revisions to Exhibits and general updates.
CPS Energy
Pole Attachment Standards
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Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Table of Contents
Section Page
I. Statement of Purpose 1
II. General Administrative Provisions 5
A. Definitions 6
B. Registration of Entity 27
1. Initial Registration Information 27
2. Updates to Registration Information 27
C. Execution of Pole Attachment Agreement 28
1. Separate Agreements Required for Wired Attachments, Wireless
Installations, and Banner Attachments
28
2. Standards Applicable Regardless of Effective Agreement 29
D. Specify Type of Attachments 30
E. Termination of Permit 30
1. Automatic Termination of Permit 30
2. Surrender of Permit 30
F. Reporting Requirements 31
1. List of Installations 31
2. List of Non-Functional Attachments 31
3. Removed Equipment 31
4. Emergency Contact 31
5. Failure to Report 32
6. Right to Audit 32
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CPS Energy
Pole Attachment Standards
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Effective Date: January 1, 2019
Section Page
G. Notices 32
1. Notice of Revisions to the Pole Attachment Standards 32
2. Process to Request Revisions to the Standards 33
H. Scope of Standards 34
1. Grant of Permit 34
2. Parties Duties and Obligations Under Standards 34
3. Permit Issuance Conditions 34
4. No Interest in Property 34
5. Non-Exclusivity 34
6. CPS Energy’s Rights over Poles 35
7. Restoration of CPS Energy Service 35
8. Permitted Uses 35
9. Expansion of Capacity 36
10. Reserved Capacity 36
11. Authorization for Use of One-Touch Transfer Process 37
I. Fees and Charges 37
1. General 37
2. Application Fee & Make-Ready Engineering Review 40
3. Advance Payment for Make-Ready Electrical Construction 40
4. Annual Attachment Connection Fee 41
5. Annual Wireless Installation Fee 42
6. Unauthorized Charge 42
7. Other 43
J. Claims 44
1. Claims for Damage to CPS Energy Facilities 44
2. Upon Receipt of Claim 44
3. Dispute of Claim 45
4. Payment of Claims 45
5. Failure to Pay Claims 45
K. Compliance with Pole Attachment Standards & CPS
Energy Enforcement
46
1. Expectation of Compliance 46
2. Enforcement of Standards 46
3. Safety Violation & Safety Violation Assessment 46
4. Failure to Enforce 48
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Pole Attachment Standards
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Section Page
L. Conflict Resolution 48
1. Informal Conflict Resolution 48
2. Formal Process 49
M. Liability Insurance and Indemnification 50
N. Indemnification 50
O. Performance Bond 50
III
.
General Technical Provisions 51
A. General Design & Construction Standards & Specifications 51
1. Professional Engineer 52
2. Contractors 52
3. Right to Review 53
4. Installation/Maintenance of Communication Facilities 53
5. Conflicts Within the Standards 54
6. Request Waiver 54
7. Tagging 55
8. Physical Interference with CPS Energy Facilities 56
9. Performance Interference to Attaching Entity’s Customer 57
10. Wireless Interference 57
11. Enclosures 59
12. Vegetation Management 60
13. Removal of Attaching Entity’s Facilities 60
14. Pre-Certification of Wireless Systems 61
B. Pole Modification and/or Replacements 62
1. Restrictions on Certain Poles 62
2. CPS Energy Not Required to Relocate 64
3. Guying 64
4. Aesthetic of Civic Projects 64
5. Underground Relocation 66
6. Customer Requested Underground Relocations 67
7. Replacement of Pole with Pole Top Antenna 68
8. Abandonment or Removal of CPS Energy Facilities 68
9. Allocation of Costs 69
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Section
Page
C. Overlashing 70
1. Application Required 70
2. Overlashing Third-Party Facilities 70
3. Annual Connection Fee 70
D. Inspection and Inventory of Attaching Entity’s Facilities 70
1. Inspections 70
2. Routine Visual Inspections and/or Inventory 71
3. Formal Inventory Performed by CPS Energy or Third Party
Contractor Subject to Competitive Bid
72
4. No Liability 74
5. Attaching Entity Conducted Inventory 74
E. Unauthorized Occupancy or Access 74
1. Unauthorized Attachments 75
2. Unauthorized Attachment and Unauthorized Wireless Installation
Charge
75
3. No Ratification of Unauthorized Use 76
4. Excessive Unauthorized Attachments 76
F. Operational Duties & Responsibilities 76
1. Duty to Inspect 76
2. Knowledge of Work Conditions 77
3. Duty of Competent Supervision and Performance 77
4. Requests to De-energize 78
5. Interruption of Service 78
6. Duty to Inform 78
7. Duty to Protect Data 79
8. Duty to Provide Safety Briefing 79
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Pole Attachment Standards
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I
V
Specifications for Wire Attachments 80
A. Pole Attachment Process 82
B. Competitive Provider - Standard Process 83
1. Eligibility 83
2. Application for Permit Required 83
3. CPS Energy Review of Application 85
4. Make-Ready Electrical Space Construction 89
Section Page
5. Make-Ready Communication Work/Installation – One Touch
Transfer
91
6. Make-Ready Communication Work/Installation – Complex Transfers 95
7. Notice of Attachment Completion and Acceptance 99
8. Post Construction Inspection 99
C. Private Network Process 101
1. Eligibility 101
2. Application for Permit Required 101
3. CPS Energy Review of Application 102
4. Make-Ready Electrical Space Construction 102
5. Make-Ready Communication Work/Installation – One Touch
Transfer
102
6. Make-Ready Communication Work/Installation – Complex Transfers 102
7. Notice of Attachment Completion and Acceptance 102
8. Post Construction Inspection 102
D. Competitive Provider – Area Wide Network Deployment
Process
103
1. Eligibility 103
2. Application for Permit Required 103
3. CPS Energy Review of Application 103
4. Make-Ready Electrical Space Construction 104
5. Make-Ready Communication Work/Installation – One Touch
Transfer
108
6. Make-Ready Communication Work/Installation – Complex Transfers 109
7. Notice of Attachment Completion and Acceptance 109
8. Post Construction Inspection
109
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E. Competitive Provider – Network Upgrade Process 110
1. Eligibility 110
2. Choice of Process 110
3. Written Notice of Choice 110
F. Competitive Provider – Standard Process for Overlashing
Existing Attachments
111
1. Eligibility 111
2. Application for Permit Required 111
3. CPS Energy Review of Application 112
4. Make-Ready Electrical Space Construction 112
5. Make-Ready Communication Work/Installation – One Touch Transfer 112
6. Make-Ready Communication Work/Installation – Complex Transfers 112
7. Notice of Attachment Completion and Acceptance 112 8. Post Construction Inspection 112 Section Page
V
.
Specifications for Wireless Installations 113
A. Wireless Installation Process 113
B. Standard Process for Wireless Installations 115
1. Eligibility 115
2. Application for Permit Required 115
3. CPS Energy Review of Application 118
4. Make-Ready Electrical Space Construction 121
5. Make-Ready Communication Work/Installation – One Touch
Transfer
124
6. Make-Ready Communication Work/Installation – Complex Transfers 127
7. Notice of Attachment Completion and Acceptance 131
8. Post Construction Inspection 131
VI.. Specifications for Banner Attachments 133
A. Banner Attachment Process
1. Eligibility 135
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2.. Application for Permit Required 135
3. CPS Energy Review of Application 136
4. Make-Ready Electrical Space Construction 137
5. Make-Ready Communication Work/Installation – One Touch Transfer 137
6. Make-Ready Communication Work/Installation – Complex Transfers 137
7. Notice of Attachment Completion and Acceptance 138
8. Post Construction Inspection 138
C. Standard Notification Process for Banner Attachment – Banner
Displays
138
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Section Page
VI. Appendices Appendix - 1
A. CPS Energy Attaching Entity Registration & Annual
Reporting Form
Appendix - 32
B. CPS Energy Pole Attachment Program Forms Appendix - 98
C. CPS Energy Notice of Dispute Form Appendix - 3525
D. CPS Energy Specification’s for Attachments &
Wireless Installations
Appendix - 3626
E. CPS Energy Vertical Clearance Requirements Appendix -
5542
F. CPS Energy Attachment Clearance Requirements Appendix -
5643
G. CPS Energy Pole Loading Requirements Appendix -
5844
H. CPS Energy Schedule of Pole Attachment Rates, Fees
and Charges
Appendix –
6046
I. CPS Energy Wireless Installation Diagrams Appendix –
6449
J. CPS Energy Banner Attachment Diagrams Appendix -
8455
K. CPS Energy Pole Attachment Tag List & Detail Appendix -
8856
L. Reserved for Future Use Appendix –
9058
M. CPS Energy Equal Opportunity & Anti-
Harassment Policy
Appendix –
9159
N. CPS Energy Information Systems Use Policy Appendix -
9563
O. CPS Energy Tree Trimming Specifications Appendix -–
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CPS Energy
Pole Attachment Standards
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SECTION I.
STATEMENT OF PURPOSE
CPS Energy
Pole Attachment Standards
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I.STATEMENT OF PURPOSE
Given the increasing and varied demands of pole use by a large number of disparate communications
providers in the San Antonio area, CPS Energy has established these Pole Attachment Standards
(Standards) to govern access to and use of CPS Energy Poles. Applicable to all communications
providers and other stakeholders for attachment of Communications Facilities, Wireless
Installations, and Banner Attachments, these Standards provide for a non-discriminatory, consistent,
and streamlined approach for the access and use of CPS Energy Poles in a manner that will facilitate
the delivery of the variety of communication services offered today, as well as to assist with speed-
to-market processes for future technologies in a manner that is consistent with the safe and reliable
operation of CPS Energy Facilities. These Standards will work to ensure that CPS Energy and all
communications providers and other stakeholders attaching to CPS Energy Poles comply with all
applicable laws, standards, regulations, and ordinances.
In adopting these Standards, CPS Energy has attempted to incorporate new and evolving best
practices and recommendations that have been developed and endorsed at the national level, such as
the Federal Communications Commission’s (FCC) recommendations in its National Broadband
Plan1 related to the ability of Attaching Entities to perform Make-Ready Work by utility-approved
and qualified contractors. Consistent with the FCC’s rules, the Standards also mirror and incorporate
national safety standards and federal requirements, such as those developed by the Occupational
Safety and Health Administration (OSHA) that are aimed at ensuring the safety of workers and
maintaining a safe work environment.2 At the same time, these Standards, like the FCC’s pole
attachment access rules, do not woodenly apply national standards when CPS Energy’s unique
operational experiences and requirements dictate the application of policies, practices, and standards
that are more stringent or different than national standards. As the FCC noted,
Despite this specificity, the introduction to the NESC [National Electric Safety Code]
states that the code "is not intended as a design specification or an instruction manual…
In addition to operating under federal, state, and local requirements, a utility normally
will have its own operating standards that dictate conditions of access. Utilities have
developed their own individual standards and incorporated them into pole attachment
agreements because industry-wide standards and applicable legal requirements are too
general to take into account all of the variables that can arise. A utility's individual
standards cover not simply its policy with respect to attachments, but all aspects of its
business…Particular utility work methods and equipment may require specific
1 Connecting America: the National Broadband Plan, at 111 (adopted Mar. 15, 2010), available at
http://transition.fcc.gov/national-broadband-plan/national-broadband-plan.pdf. 2 https://www.osha.gov/as/opa/worker/employer-responsibility.html
CPS Energy
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separations between attachments and may restrict the height of the poles that a utility
will use… The number of variables makes it impossible to identify and account for them
all for purposes of prescribing uniform standards and requirements. Universally
accepted codes such as the NESC do not attempt to prescribe specific requirements
applicable to each attachment request and neither shall we.3
While CPS Energy has looked to FCC pole attachment access rules for guidance, CPS Energy is not
bound by such regulations. State law requires CPS Energy to provide Certificated Providers and
Wireless Providers with non-discriminatory access to its utility distribution poles for the purpose of
installing wire Attachments and Wireless Installations, respectively. In addition, CPS Energy must
establish annual pole attachment rates at a level not to exceed the rate that would result from the
application of the FCC’s telecommunications pole attachment formula. Otherwise, the federal Pole
Attachment Act and the FCC’s pole attachment regulations are not applicable to CPS Energy.
Private Networks Attachments and Banner Attachments fall outside the scope of these legal
requirements. Nevertheless CPS Energy will grant non-discriminatory access to its Poles for Private
Networks Attachments and Banner Attachments taking into account the burdens that these and all
other Attachments place on CPS Energy Facilities.
Consistent with these legal requirements and the voluntary commitment of CPS Energy, under these
Standards, wire Attachments may be installed on CPS Energy’s utility distribution Poles. Wireless
Installations will have access to utility distribution Poles and Overhead Streetlight Poles, subject to
certain restrictions and Make-Ready Work requirements. Banner Attachments will have access to
utility distribution Poles and Streetlight Poles, subject to certain restrictions and Make-Ready Work
requirements. Consistent with the rate design for wire Attachments, which is based on the rental of
one foot of pole space, and pursuant to Chapter 284 of the Texas Local Government Code, Wireless
Installations will be assessed annual rent based on the number of feet of Pole use.
From a holistic perspective, the Standards seek to balance the competing needs and interests of
multiple and varied communications providers and other eligible stakeholders to access and utilize
CPS Energy’s distribution infrastructure, while at the same time recognizing that the core purpose
and function of this infrastructure is for CPS Energy’s safe and reliable distribution and delivery of
electric services to CPS Energy customers. Hence, the use of any CPS Energy’s Poles or other
facilities must at all times ensure the continued operational integrity, safety, and reliability of CPS
Energy’s Facilities, electric services, personnel, and the general public.
3 In the Matter of Implementation of the Local Competition Provisions in the Telecommunications Act of 1996, First
Report and Order, ¶ ¶ 1147-1149 (rel. August 8, 1996)
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These Standards are organized into seven parts:
Section I this introductory section explaining the purpose of the Standards
Section II sets out general administrative provisions
Section III sets out general technical provisions
Section IV sets out the specifications applicable to wire Attachments
Section V sets out the specifications applicable to Wireless Installations
Section VI sets out the specifications applicable to Banner Attachments
Section VII contains the Appendices referenced in these Standards
Upon their effective date, these Pole Attachment Standards shall be enforceable by CPS
Energy at all times upon any entity that attaches its facilities to a CPS Energy-owned Pole
regardless of the status of any type of contract Pole Attachment Contract, Application, or
Permit.
These Standards shall be interpreted liberally. It is CPS Energy’s intent to apply generally applicable
requirements in a similar manner to all Attaching Entities, and to avoid interpretations that are
contradictory, irrational, or unfair. These Standards are intended to apply in a non-discriminatory
manner; however, this does not mean the same treatment under all circumstances or to differently
situated Attaching Entities. CPS Energy reserves the right to interpret these Standards consistent
with the guiding principles of ensuring safety, network reliability, and customer service. At no time
shall these Standards be interpreted to jeopardize safety, network reliability, or customer service.
CPS Energy reserves the right to amend these Standards at any time and manner in response to
market conditions and as necessary to comply with changes in applicable engineering and/or safety
standards or changes in local, state or federal law. Any such changes will be applied in a non-
discriminatory manner with respect to similarly situated entities and facilities.
To the extent that issues arise that have not been contemplated by these Standards, CPS Energy will
work with the Attaching Entities to find a solution that effectively addresses the issue consistently
with these Standards.
These Standards supersede all prior CPS Energy pole attachment rules and regulations.
Amendments to these Standards will become effective following a notice period as provided in this
document and the return of a letter accepting the amendments, as provided in the applicable Pole
Attachment Contract.
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SECTION II.
GENERAL
ADMINISTRATIVE
PROVISIONS
CPS Energy
Pole Attachment Standards
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II.GENERAL ADMINISTRATIVE PROVISIONS
A. Definitions
For the purposes of these Standards, the following terms, phrases, words, and their
derivations shall have the meaning given herein. When not inconsistent with the context,
words used in the present tense include the future tense, words in the plural number include
the singular number, and words in the singular number include the plural number. The words
“shall” and “will” are mandatory and “may” is permissive. Words not defined shall be given
their common and ordinary meaning.
1. Affiliate means, when used in relation to an Attaching Entity, another entity that
owns or controls, is owned or controlled by, or is under common ownership or control
with the Attaching Entity.
2. Antenna means an FCC authorized electrical device by which electromagnetic
waves are sent out or received. Antennas are inventoried Wireless Installation
components.
3. Antenna Area means the area on a Pole or Overhead Streetlight Pole where the
Antenna is installed, which is a component of a Wireless Installation. For a Wireless
Installation that utilizes the top of a Pole, the Antenna Area shall be the Pole Top
Space.
4. Applicable Engineering Standards means all applicable engineering and/or safety
standards governing the installation, maintenance, and operation of facilities, and the
performance of all work in or around CPS Energy’s Facilities and includes CPS
Energy’s clearance standards, the National Electrical Safety Code (NESC), the
National Electrical Code (NEC), the Texas Health & Safety Code, Chapter 752
(Vernon 1992) and any subsequent amendments which relate to the maintenance of
proper clearances and related safety issues, the regulations of the Occupational Safety
and Health Act (OSHA), applicable regulations of the Federal Communications
Commission (FCC), the Environmental Protection Agency (EPA), lawful
requirements of Public Authorities, and/or other requirements of CPS Energy that are
non-discriminatory to each Attaching Entity as compared to all other similarly
situated Attaching Entities and types of facilities.
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5. Application means a complete Application for a Permit submitted by an Attaching
Entity to CPS Energy for the purpose of requesting consent to install a new
Attachment, Overlash, Wireless Installation, or Banner Attachment onto or supported
by one or more CPS Energy Poles or Streetlight Poles, as appropriate. Mid-Span
Installations do not require Applications, but a Notification of Mid-Span Installations
(as defined below) instead.
6. Application Fee means the non-refundable fee described in Appendix H of these
Standards, compensating CPS Energy for the administrative and other work required
to process and review an Application.
7. Application Form means the form(s), provided in Appendix B, an Attaching Entity
is required to submit to CPS Energy, along with all applicable documents, as part of
a complete Application in order to request a Permit. Such forms include the
Application for Pole Attachment Permit, Application for Wireless Installation Permit,
and Application for Banner Permit. A Mid-Span Installation does not require an
Application; rather, an Attaching Entity seeking to attach a Mid-Span Installation
shall submit the “Mid-Span Installation Notification Form” found in Appendix C,
along with all applicable supporting information and documentation.
8. Attaching Entity means any eligible person, public entity, or private company or
corporation that places a wire Attachment, Banner Attachment, or Wireless
Installation on a CPS Energy Pole or Streetlight Pole, as appropriate, in accordance
with CPS Energy’s applicable requirements, including an applicable contract Pole
Attachment Contract and these Standards, to provide Communications Service,
Wireless Service, or Commercial Mobile Radio Service, operate a Private Network,
or provide Banner Advertisement service. Throughout these Standards, the term
“Attaching Entity” includes a Wireless Provider and Banner Attacher, as appropriate
in context.
9. Attaching Entity Registration & Annual Reporting Form means the initial
registration form, provided in Appendix A, a Requestor must submit in order to enter
into a Pole Attachment, Wireless Installation, or Banner Attachment Agreement, as
appropriate, with CPS Energy; and which must be updated annually by September 1st
of each year, or as changes warrant.
10. Attachment means (a) each aerial cable together with its associated Messenger cable,
guy wire, anchors, and associated hardware, and each amplifier, repeater, receiver,
appliance or other device or piece of equipment, whether comprised of steel,
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aluminum, copper, coaxial, optical fiber, or other media or material utilized to
provide Communications Services; and (b) any hardware or equipment identified as
(i)in Section II.A.25a Communications Facility affixed to a CPS Energy Pole
utilizing one foot or less of Communication Space, or (ii) a Mid-Span Installation
utilizing the same one foot of Communication Space as the Messenger cable to which
it is attached.. An Attachment occurs whether Attaching Entity’s Communications
Facilities are connected to the Pole itself or are supported by an Attachment Arm,
bracket, support stand, or other support devices, provided however that Overlashing
an existing permitted Attachment and Service Drops shall not count as separate
Attachments. This definition shall not apply to communications wires or facilities
installed by CPS Energy for its own internal communications requirements or energy
Information Services such as automated meter reading.
11. Attachment Arm means a CPS Energy approved metal or fiberglass bracket used to
support attaching wires away from the face of the Pole in order to clear risers or other
obstacles. Standoff brackets will not be allowed for the specific purpose of achieving
the forty (40”) inch vertical clearance from the Neutral as required by Applicable
Engineering Standards.
12. Attachment Connection Fee means the total annual rental payment assessed by CPS
Energy to each Attaching Entity determined by multiplying [Attachment Rate] x
[total number of permitted Attachments for the Attaching Entity], as described in
Appendix H.
13. Attachment Rate means the annual rate for one foot of space as determined by CPS
Energy consistent with Texas Utilities Code, §54.204(c).
14. Authorization for Make-Ready Work means the form, provided in Appendix B,
CPS Energy shall issue to an Attaching Entity that request’s the Attaching Entity’s
authorization for CPS Energy to undertake Make-Ready Electrical Construction. The
Authorization for Make-Ready Work form shall also provide an estimate for the
advanced payment cost required to be paid for the Make-Ready Electrical
Construction.
15. Backhaul Network Interface Device means the network interface enclosure that
mark the location where a Communications Facility interconnects with a pole-
mounted Wireless Installation for the purpose of providing telecommunications
transport service between the Wireless Installation and the host network. The
Backhaul Network Interface Device shall be considered the point of demarcation
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between the Wireless Installation and the provider of telecommunications transport
service.
16. Banner means a temporary sign made of light weight fabric affixed to or supported
by one or two Poles or Streetlight Poles in compliance with Section 28-6 of the City
of San Antonio Code of Ordinances, or the appropriate city ordinance of a suburban
city within CPS Energy’s service area where the pole structures supporting the
temporary sign are located on Public Right of Way. A Banner may be Single Pole
Banner or Double Pole Banner.
17. Banner Attacher means the person, public entity, or private company or corporation
that has executed a Banner Attachment Agreement and is authorized to affix the pole-
mounted hardware components of a Banner Attachment to a Pole or Streetlight Pole
and to temporarily display a Single Pole Banner or Double Pole Banner.
18. Banner Attachment means permanently installed pole-mounted anchors, guy wires,
hooks, brackets, fasteners, and related hardware installed on a Pole or Streetlight Pole
for the purpose of supporting or suspending a Single Pole Banner or Double Pole
Banner.
19. Banner Attachment Agreement means an executed agreement between CPS
Energy and a Requestor that grants a general license to access Poles and/or Streetlight
Poles for the purpose of installing Banner Attachments and Banners pursuant to the
specifications of these Standards, and adopts and incorporates these Standards by
reference, and under which the Requestor agrees to abide by the terms and conditions
of the agreement as well as duties and obligations of these Standards as they may be
amended from time to time. The agreement shall include additional legal protections
and obligations of the parties not specifically covered in the Standards. A Banner
Attachment Agreement may be referred to generally in the Standards as a “Pole
Attachment Contract.”
20. Banner Advertisement means the private or commercial speech which makes up the
content of a Banner and which is regulated within their respective jurisdictional
boundaries by the City or other suburban cities located within CPS Energy’s service
area.
21. Banner Attachment Rate means the same annual rental rate as the Attachment Rate.
22. Banner Attachment Connection Fee means the total annual rental payment
assessed by CPS Energy to each Banner Attacher determined by multiplying [Banner
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Pole Attachment Standards
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Attachment Rate] X [Total number of permitted Banner Attachments] X [Total
number of pole feet reserved by the Banner Attachment hardware to display
Banners].
23. Banner Permit means the written or electronic authorization from CPS Energy
related to Banner Attachment hardware mounted unto a Pole or Streetlight Pole and
pursuant to applicable city ordinance signage regulations, and the requirements of the
Banner Attachment Agreement and these Standards.
24. Cabinet Area means the area of a Pole excluding Overhead Streetlight Pole where
the Wireless Equipment Cabinet and Backhaul Network Interface Device are
installed adjacent to each other as part of a Wireless Installation. For a Wireless
Installation that does not utilize the top of a Pole, the Cabinet Area shall be located
below the Antenna Area.
25. Cable Services means the provision of one-way transmission to subscribers of video
programming, or other programming service, and subscriber interaction, if any,
which is required for the selection or use of such video programming or other
programming service by a cable system. Cable Services shall not include Information
Services or Video Services, as defined in the Texas Utilities Code §66.002.
26. Capacity means the ability of an existing Pole to accommodate an additional
Attachment, Overlash, Wireless Installation, or Banner Attachment based on
Applicable Engineering Standards, including space, design, and loading
considerations.
27. Certificated Provider means a competitive service provider of Communications
Services, Cable Services, or Video Services that has received a Certificate of
Convenience and Necessity, Certificate of Operating Authority, Service Provider
Certificate of Operating Authority, or State Issued Certificate of Franchising
Authority from the Public Utility Commission of Texas.
28. City means the City of San Antonio, Texas.
29. Civic Project means any specific project that requires adjustments of CPS Energy
Poles, Streetlight Poles, or other CPS Energy Facilities to accommodate federal, state,
city, or county roadway reconstruction/widening, drainage improvements, or other
type of civic improvement project (reimbursable to CPS Energy or not) within the
Public Right of Way.
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30. Commercial Mobile Radio Service or CMRS has the meaning given by federal law
at 47 C.F.R. §203.3.
31. CMRS Provider means an FCC-authorized provider of CMRS.
32. Collection Notice Letter means a letter of notification produced by the CPS Energy
Claims Department itemizing charges owed to CPS Energy as a result of damages to
CPS Energy Facilities caused by an Attaching Entity, or its contractors,
subcontractors, or agents, or by a third-party causing damage to the Attaching
Entity’s Attachments, Communication Facilities, Wireless Installations, or Banner
Attachments and by extension to CPS Energy Facilities. This letter constitutes CPS
Energy’s tender for recovery of all costs associated with repairs to the damaged
facilities.
33. Communications Facility means a wire or cable facilities including, but not limited
to, a fiber optic, copper and/or coaxial cable or wire utilized by an Attaching Entity
to provide Communications Services, including any and all associated equipment. A
Communications Facility also includes a Messenger or other material, appurtenance,
or apparatus of any sort necessary or desirable for use in the provision of an Attaching
Entity’s Communications Services. A Communication Facility shall not include an
Antenna or wireless Remote Radio HeadWireless Equipment.
34. Communications Services means the provision of service, including but not limited
to Telecommunications Services, Cable Services, Video Services, or Information
Services over wire or cable facilities utilizing Attachments to Poles. This definition
excludes Attachments made by private entities and public organizations, such as
schools, universities, and units of local government, that operate a Private Network
used for non-commercial communications purposes.
35. Communications Space means the portion of a Pole’s usable space designated for
the installation of Communications Facilities, the top of which is forty (40) inches
below CPS Energy’s Neutral or lowest electrical supply conductor.
36. Communication Worker Safety Zone means that space on a Pole measured from
the location of the Neutral to a location forty (40) inches below the Neutral as
described in the NESC.4
4 NESC, Rule 235.C.4 and 238.E, C2-2017.
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37. Competitive Provider – Area Wide Network Deployment Process means the
Application submission and Permit approval process applicable to a Certificated
Provider engaged in a broadband network deployment within the CPS Energy service
area characterized by an Attaching Entity’s submission of Applications to attach or
Overlash to Poles that would result in an estimated replacement of eighty (80) or
more Poles per month; and the responsibility to prepare Make-Ready Engineering,
manage Make-Ready Electrical Construction and Make-Ready Communications
Construction, and incur all expenses associated with Make-Ready Work.
38. Competitive Provider – Network Upgrade Process means the Application
submission and Permit approval process applicable to a Certificated Provider
engaged in a broadband network deployment within the CPS Energy service area;
and the responsibility to prepare Make-Ready Engineering, manage Make-Ready
Communications Construction, the option to manage Make-Ready Electrical
Construction, and incur all expenses associate with Make-Ready Work.
39. Completion of Attaching Entity Construction means the form, provided in
Appendix B, an Attaching Entity shall issue to CPS Energy providing written notice
of completion of either (1) Make-Ready Communication Construction, (2) Make-
Ready Wireless Installation Construction, (3) Make-Ready Electrical Construction,
or (4) Make-Ready Banner Attachment Construction as appropriate.
40. Complex Transfer means the transfer or relocation of a third-party Attachment or
Overlash onto a CPS Energy Pole that will require cutting and splicing of a
Communication Facility resulting in a network and/or customer outage affecting the
Attaching Entity that owns the Communication Facility subject to transfer or
relocation, or the transfer or relocation of such an Attached or Overlash
Communication Facility located over and across a state or federal highway.
41. Customer means a CPS Energy electric customer that has established an electric
service account and that is receiving the electric service at a specified point of
delivery from CPS Energy’s electric distribution system in compliance with CPS
Energy’s Electric Service Standards and all applicable local, state, and federal codes
and regulations.
42. CPS Energy Facilities means all personal property and real property owned or
controlled by CPS Energy, including Poles and Streetlight Poles.
43. Critical Communications Facility means a Communications Facility that must
provide “always on” connectivity for public safety communications or public health
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operations whose failure would pose a potential imminent threat to public health or
safety.
44. Deployment Plan means a document prepared by an Attaching Entity that shall
include: (1) footprint of the network buildout illustrated in a map depicting the
municipal jurisdiction, or parts thereof, within the CPS Energy service area expected
to be covered by the project; (2) overall network deployment schedule and phasing;
(3) map of backbone fiber rings routes, if any; (4) description of overall physical plant
architecture and design; (5) description of typical Service Drop installations; (6)
estimated number of Poles expected to be attached to including a reasonable “ramp-
up” and “ramp-down” plan; (7) project and corporate organizational chart for the
Attaching Entity; and (8) signature page attesting to the veracity of the Deployment
Plan executed by an authorized officer of the Attaching Entity. A Deployment Plan
is required only under the Competitive Provider – Area Wide Network Deployment
Process and the Competitive Provider – Network Upgrade Process.
45. Distributed Antenna System or DAS Systems means an outdoor system of Antenna
nodes and associated Wireless Equipment Cabinets attached to Poles or Overhead
Streetlight Poles interconnected by one or more fiber or coaxial cable
Communication Facilities and supported by communications equipment and
components housed within a hut structure located on private or public property away
from CPS Energy Facilities.
46. Double Pole Banner means a horizontally installed Banner made of light weight
fabric, non-toxic material, with 1/12” to 4” open-weave nylon or polyester net, with
dimensions not to exceed 36’ x 4’ which may be temporarily affixed across or along
a Public Right of Way supported by a guy wire running along the top of the Banner,
attached to two Poles, and installed below the Communications Space.
47. Electrical Space or Supply Space means the upper portion of a Pole reserved for
the installation of electric distribution facilities to support existing and planned
electric distribution equipment as described in the NESC.
48. Emergency means the existence of a situation which, in the reasonable discretion of
CPS Energy or the Attaching Entity, if not remedied immediately will result in a
threat to public safety, a hazardous condition, damage to property or a service outage.
49. Engineer means any licensed professional engineering firm approved by CPS
Energy to complete Engineering work on CPS Energy Facilities.
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50. Federal Communications Commission (FCC) means the independent federal
agency established to regulate, in the public interest, communications by radio and
wire.
51. Information Services means the offering of a capability for generating, acquiring,
storing, transforming, processing, retrieving, utilizing, or making available
information via telecommunications, and includes electronic publishing and cable
modem service, but does not include any use of any such capability for the
management, control, or operation of a telecommunications system or the
management of a telecommunications service.
52. Infrastructure Provider means an Attaching Entity that is a Wireless Provider,
which may or may not be a Certificated Provider, that owns no licensed frequencies,
but that invests in Wireless Installations for the purpose of leasing its
Communications Facilities and Wireless Installations to a CMRS Provider that
utilizes such facilities to embed proprietary technology that allows the leased
facilities to transmit and receive the CMRS Provider’s licensed frequencies. Such
leased facilities are interconnected with the CMRS Providers wireless network to
expand network capacity.
53. Infrastructure Provider Sublicensee means a CMRS Provider that leases
Communication Facilities and Wireless Installations from an Infrastructure Provider
for the purpose of providing or expanding wireless network capacity that has
executed an Infrastructure Provider Sublicensee Wireless License Agreement.
54. Infrastructure Provider Sublicensee Wireless License Agreement means an
executed agreement between CPS Energy and an Infrastructure Provider Sublicensee
that grants a license to use CPS Energy Poles and Overhead Streetlight Poles, as
appropriate, for the purpose of operating a wireless network. The agreement
recognizes, among other issues, that the Infrastructure Provider Sublicensee leases
Wireless Installations owned by an Infrastructure Provider and that CPS Energy shall
look to the Infrastructure Provider for compliance with these Standards, but otherwise
the Infrastructure Provider Sublicensee has a duty to ensure that its proprietary
technology and FCC licensed frequencies do not result in any Wireless Interference
with CPS Energy’s wireless systems and equipment. The agreement includes
additional legal protections and obligations of the Parties not specifically covered in
the Standards. An Infrastructure Provider Sublicensee Wireless License Agreement
may be referred to generally in the Standards as a “Pole Attachment Contract.”
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55. Intermodulation Test means a report that contains a mathematical model identifying
potential Wireless Interference based on computational harmonic mixing of proposed
and existing transmit and receive frequencies in the immediate vicinity.
55.56. Inventory means a complete count of all Authorized and Unauthorized Attachments,
Banner Attachments, and Wireless Installations on CPS Energy owned Poles and
Streetlight Poles within the CPS Energy service territory.
56.57. Joint Meeting Transfer means the coordinated transfer of a pole-mounted Wireless
Installation by its owner to take place at the same time as an Attaching Entity
schedules the installation of a new Attachment, Overlash, or Mid-span Installation
onto or supported by the same Pole that hosts the Wireless Installation, which requires
adjustments of existing Attachments or Pole replacement as part of the One-Touch
Transfer Process.
57.58. Inventory means a complete count of all authorized and unauthorized Attachments,
Banner Attachments, and Wireless Installations on CPS Energy-owned Poles and
Streetlight Poles within the CPS Energy service territory.
58.59. Make-Ready Banner Attachment Construction means that portion of Make-
Ready Work associated with construction work required to install a Banner
Attachment necessary to support a Double Pole Banner below the Communications
Space of a Pole, or a Single Pole Banner on a Streetlight Pole, including, but not
limited to the movement, transfer, relocation, or modification of an existing
Attachment or Overlash, or Mid-span Installation; the replacement of a Pole; and all
other construction activities necessary to accommodate the hardware components of
the Banner Attachment.
59.60. Make-Ready Charges means all reasonable administrative, engineering design,
construction, inspection, and management charges associated with Make-Ready
Work.
60.61. Make-Ready Communication Construction means that portion of Make-Ready
Work associated with construction work requiring access to Communication
Facilities within the Communication Space of a Pole, including, but not limited to the
movement, transfer, relocation, or modification of an existing Attachment Overlash,
or Mid-span Installation; the replacement of a Pole; and all other construction
activities necessary to accommodate the installation of a new Attachment Overlash,
or Mid-span Installation. Make-Ready Communications Construction shall include,
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where applicable, the nexus between aerial and underground communication
construction.
61.62. Make-Ready Electrical Construction means that portion of Make-Ready Work
associated with construction work requiring access to CPS Energy Facilities within
the Electrical Space, which includes, but is not limited to the movement, transfer,
relocation, or modification of CPS Energy electric distribution facilities; the
replacement of a Pole; and all other construction activities necessary to accommodate
the installation of a new Attachment, Overlash, or Wireless Installation. Make-Ready
Electrical Construction shall include, where applicable, the nexus between aerial and
underground electrical construction.
62.63. Make-Ready Engineering means that portion of Make-Ready Work associated with
the preparation, submission, review, and approval of the Attaching Entity’s
Application for Attachment, Banner Attachment, or Wireless Installation Permit.
Make-Ready Engineering shall include, but not limited to, the preparation of the
following in support of the Application: the Pre-Construction Survey; the engineering
design document(s) for Make-Ready Electrical Construction, Make-Ready
Communications Construction, Make-Ready Banner Attachment Construction, and
Make-Ready Wireless Installation Construction; and the submission of such
documents to CPS Energy for review, potential modification, and approval. Make-
Ready Engineering shall include, where required, the approval of a professional
engineer, and the engineering design specifications related to the nexus between
aerial and underground construction of Communications Facilities as part of Make-
Ready Communications Construction of a Wireless Installation as part of Make-
Ready Wireless Construction, and of electrical distribution facilities as part of Make-
Ready Electrical Construction.
63.64. Make-Ready Wireless Installation Construction means that portion of the Make-
Ready Work associated with construction work requiring access to a Pole below the
Communications Space and the Pole Top Space, as appropriate, or to access the
Communication Space of pole structures to support a Mid-span Installation,
including, but not limited to the movement, transfer, relocation, or modification of an
existing Attachment or Overlash when a pole structure replacement is necessary or
otherwise in order to accommodate the Wireless Installation components; and all
other construction activities necessary to accommodate the Wireless Installation on,
or supported by, a pole structure. Make-Ready Wireless Installation Construction
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shall include, where applicable, the nexus between aerial and underground
communications construction.
64.65. Make-Ready Work means all work that is required to accommodate an Attaching
Entity’s Attachment, Overlash, Wireless Installation, or Banner Attachment onto a
Pole or Streetlight Pole, as appropriate, in compliance with the Applicable
Engineering Standards. Make-Ready Work may include, but is not limited to, Make-
Ready Engineering, Make-Ready Electrical Construction, Make-Ready
Communications Construction, Make-Ready Wireless Installation Construction, and
Make-Ready Banner Attachment Construction; along with CPS Energy’s review of
the Application, engineering design documents, Pole Loading Analysis documents,
engineering work, construction work, permitting work, tree trimming (other than tree
trimming performed for normal maintenance purposes), Pole or Streetlight Pole
replacement, and the Post-Construction Inspection.
65.66. Messenger means any cable owned by an Attaching Entity extending between Poles
which is used as support for a Communications Facility or upon which a Mid-Sspan
Installation is clamped.
66.67. Meter means the device or any auxiliary equipment installed by CPS Energy to
measure electric energy consumed by the Wireless Equipment as provided in CPS
Energy Electric Service Standards.
67.68. Meter Area means the area of a pole structure where the Meter and Service
Disconnection Switch are mounted on such pole from ground-level to the top of the
Service Disconnection Switch.
68.69. Mid-Span Installation means Wireless Equipmenta Wireless Installation consisting
of a “mMicro network node,” as that term is defined in chapter 284 of the Texas Local
Government Code,. attached to a Messenger cable suspended between two Poles, in
the Communication Space, that was manufactured for this type of installation and
designed to connect by means of an Overlashed Communications Facility for the
purpose of providing Wireless Service.
69.70. National Electrical Safety Code (NESC) means the current edition published by the
Institute of Electrical and Electronic Engineers (IEEE) as may be amended or
supplemented from time-to-time.
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70.71. National Joint Utilities Notification System (NJUNS) means the national not-for-
profit organization that helps support effective communication between utilities and
Attaching Entities.
71.72. Network Operations Center (NOC) means a centralized location from which an
Attaching Entity administrators remotely supervises, monitors, and maintains the
day-to-day operations of a network. The scope of responsibilities of a NOC may be
national or regional in nature.
72.73. Neutral means the conductor used to carry unbalanced current. In single-phase
systems, the conductor used for a return current path.
73.74. Notice of Dispute Form means the form that an Attaching Entity must use to dispute
CPS Energy’s determination of liability associated with a claim for damages caused
to CPS Energy Facilities by the Attaching Entity, or its contractors, subcontractors,
or agents. This form is provided in Appendix C.
74.75. Notice to Proceed means the form, provided in Appendix B, CPS Energy shall issue
to an Attaching Entity that provides written notification that the Attaching Entity may
proceed with either (1) Make-Ready Communication Construction, (2) Make-Ready
Wireless Installation Construction, or (3) Make-Ready Electrical Construction, as
appropriate.
75.76. Notice of Safety Violation means the form, provided in Appendix B, CPS Energy
shall issue to an Attaching Entity providing written notice of CPS Energy’s
identification of a Safety Violation with one or more of the Attaching Entity’s
Attachments, Banner Attachments, Overlashings, or Wireless Installations.
76.77. Notice of Safety Violation Assessment Charge means the form, provided in
Appendix B, CPS Energy shall issue to an Attaching Entity providing written notice
of the levying of a Safety Violation Assessment Charge to the Attaching Entity.
78. Notice of Unauthorized Attachment or Unauthorized Wireless Installation
means the form, provided in Appendix B, CPS Energy shall issue to an Attaching
Entity providing written notice of CPS Energy’s identification of an Unauthorized
Attachment or Unauthorized Wireless Installation owned by the Attaching Entity.
77.79. Notification of Mid-Span Installation means a complete “Mid-Span Installation
Notification Form” found in Appendix B, together with applicable supporting
information and documentation for the purpose of notifying CPS Energy of an
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Attaching Entity’s intent to install a new Mid-Span Installation supported by one or
more CPS Energy Poles.
78.80. One-Touch Transfer mean the transfer, relocation, or alteration of third-party
Attachment Communication Facilities or Mid-span Installations whether conducted
by an Attaching Entity or CPS Energy subject to the requirements described in
Section IV.B.5, and Section V.B.5.
79.81. Overhead Streetlight Pole means a Streetlight Pole whose luminaire is fed by aerial
electrical distribution facilities owned by CPS Energy.
80.82. Overlash (or Overlashing) means to place an additional wire or cable
Communications Facility onto an existing Attachment or Messenger already secured
to the Pole in order to accommodate additional wire or cable Communications
Facility capacity. An Overlash does not include a Mid-span Installation.
81.83. Pedestals/Vaults/Enclosures means above- or below-ground housings that are used
to enclose a cable/wire splice, power supplies, amplifiers, and passive devices and/or
provide a service connection point and that shall not be attached to CPS Energy Poles.
82.84. Permit (Permit for Attachment, Banner Attachment, or Wireless Installation)
means the written or electronic authorization from CPS Energy to make or maintain
an Attachment, Banner Attachment, Overlash, or Wireless Installation to a specific
CPS Energy Pole or Streetlight Pole, as appropriate, pursuant to the requirements of
an applicable Pole Attachment Contract and these Standards. For the purpose of a
Mid-Span Installation, an Attaching Entity will obtain a Permit from CPS Energy
after successful completion of the Post-Construction Inspection at the conclusion of
the Notification of Mid-Span Installation process pursuant to Section V.C.
83.85. Pole means an electric distribution system utility pole owned by CPS Energy carrying
primary and/or secondary voltages with phase to neutral voltages up to and including
20 kilovolts (kV),
84.86. Pole Attachment Agreement means an executed agreement between CPS Energy
and a Requestor that grants a general license to access Poles for the purpose of
installing Attachments, Mid-Span Installations and Overlashes pursuant to the
specifications of these Standards, adopts and incorporates these Standards by
reference, and under which the Requestor agrees to abide by the terms and conditions
of the agreement as well as the duties and obligations set out in these Standards as
they may be amended from time to time. A Pole Attachment Agreement shall include
additional legal protections and obligations of the parties not specifically covered in
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the Standards. A Pole Attachment Agreement may be referred to generally in the
Standards as a “Pole Attachment Contract.”
85.87. Pole Attachment Program means the development, implementation, and operation
of the CPS Energy Pole Attachment Standards including but not limited to the
execution of applicable Pole Attachment Contracts, communications with
stakeholders regarding the accommodation of Attachments, Banner Attachments, and
Wireless Installations, review of Applications, completion of appropriate Make-
Ready Work, inspection of Make-Ready Work, issuance of Permits, coordination of
networks deployments and expansions, resolution of conflicts and disputes, provision
of applicable invoices, conducting workshops, accepting stakeholder input, amending
the Standards as appropriate, enforcing the Standards, conducting Inventories, and all
other general program administration and duties.
86.88. Pole Attachment Standards (or Standards) means these “CPS Energy Pole
Attachment Standards” with an initial effective date of August 1, 2016, and as
amended from time to time.
87.89. Pole Attachment Standards Revision Request (PASRR) means the form, provided
in Appendix B, any stakeholder shall submit to CPS Energy to propose a revision(s)
to these Standards.
88.90. Pole Attachment Standards Revision Request (PASRR) Comment Form means
the form, provided in Appendix B, any stakeholder shall submit to CPS Energy in
which the stakeholder may provide comments to a PASRR during the PASRR’s
comment period.
89.91. Pole Top Antenna means an Antenna that is a component of a Wireless Installation,
which is installed in the Pole Top Space of a Pole or Overhead Streetlight Pole.
90.92. Pole Top Space means the top portion of a Pole or Overhead Streetlight Pole
designated for the installation of up to three (3) enclosed Antennas which are
components of a Wireless Installation, the bottom of which shall begin one inch (1”)
above the highest electrical supply conductor and continue for sixty inches (60”) as
the clearance between the conductor and the Pole Top Antenna. For Wireless
Installations that utilize the top of a pole structure, the Pole Top Space shall be
considered the Antenna Area.
91.93. Post-Construction Inspection means the survey inspection required by CPS Energy
to determine and verify that the Make Ready Electrical Construction, Make-Ready
Communications Construction, Make-Ready Wireless Installation Construction,
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Make Ready Banner Attachment Construction and all other Make-Ready Work,
including the installation of an Attachment, Banner Attachment, Overlash, and/or
Wireless Installation was made in accordance with Applicable Engineering
Standards, the Application, and all other Permit requirements.
92.94. Pre-Certified Equipment means Wireless Equipment for which the Attaching
Entity has submitted manufacturing specifications and information to CPS Energy
for review and approval and that CPE Energy has approved or pre-certified.
93.95. Pre-Construction Survey means the field survey and all other work and operations
required by Applicable Engineering Standards to determine the Make-Ready Work
necessary to accommodate an Attaching Entity’s Communications Facilities or
Wireless Installation onto a Pole or Overhead Streetlight Pole as appropriate. Such
work includes, but is not limited to, field inspection and administrative processing.
The field survey to be done prior to preparation of Make-Ready Engineering shall be
conducted by the Attaching Entity’s Engineer or other qualified employee or agent.
94.96. Private Network means a communications network constructed for the purpose of
meeting the internal communications needs a public or private entity that is an
Attaching Entity, but which is not a Certificated Provider, Wireless Provider, or
CMRS Provider and is not in the business of providing Communications Services or
Wireless Services to the general public for a profit.
95.97. Public Right of Way means the area on, below, or above a public roadway, highway,
street, public sidewalk, alley, waterway, or utility easement in which the City of San
Antonio or other governmental entities within the CPS Energy service area has an
interest.
96.98. Receiver means any electronic device the purpose of which is to collect, amplify,
and/or control radio frequencies.
97.99. Remote Radio Heads (RRH) means a transceiver with transmitting and receiving
capability of radio frequencies. The RRH will be served by optical fiber, direct-
current power, and output to a single or multiple Antennas. Remote Radio Heads are
an inventoried Wireless Installation component.
98.100.Request for Pre-Certification of Wireless System means the form, provided in
Appendix B, an Attaching Entity shall submit to CPS Energy to request CPS Energy
to review and approve Pre-Certified Equipment for a Wireless Installation.
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99.101.Request for Temporary Attachment means the form, provided in Appendix B, an
Attaching Entity shall submit to CPS Energy to request permission to install a
temporary Attachment.
100.102. Request for Waiver of Applicable Engineering Standards (Waiver
Request) means the form, provided in Appendix B, an Attaching Entity shall submit
to CPS Energy to request a waiver of one or more Applicable Engineering Standards.
101.103. Requestor means an eligible entity that submits an Attaching Entity
Registration & Annual Reporting Form in order to enter into a Pole Attachment
Agreement, Wireless Installation Agreement, or Banner Attachment Agreement with
CPS Energy under which it may submit Applications for Permits to access CPS
Energy’s Poles or Streetlight Poles for the purpose of installing Attachments,
Overlashings, Banner Attachments, or Wireless Installations, as appropriate.
102.104. Reserved Capacity means Capacity or space on a Pole or Overhead
Streetlight Pole that CPS Energy has identified and reserved for its own core electric
utility service and lighting requirements, including space for any and all associated
internal communications functions that are essential to the proper operations of such
core electric utility service, pursuant to reasonable projected need.
103.105. Riser means metallic or plastic encasement materials supported by metal
standoff brackets placed vertically on a Pole or Overhead Streetlight to guide and
protect communication wires and cables where they transition from overhead to
underground or vice-versa.
104.106. Safety Briefing means a document or presentation materials prepared by a
Wireless Provider and provided to CPS Energy to educate CPS Energy employees
and contractors regarding specific process on how to work safely near and/or around
the Wireless Provider’s specific Wireless Installation technologies and locations.
105.107. Safety Violation means a violation of the Applicable Engineering Standards
which: (a) is reasonably expected to endanger life or property; or (b) poses a potential
safety risk to any CPS Energy or Attaching Entity employee or contractor, or to the
general public.
106.108. Safety Violation Assessment Charge means the charge payable by an
Attaching Entity for a Safety Violation as described in Appendix H.
107.109. Service Drop means a single wired drop installed to provide
Communications Service to an individual customer measured from the customer
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premises to the closest available Pole without requiring any additional anchors or
guys to comply with all Applicable Engineering Standards. Unless otherwise stated
herein, Service Drops are subject to all terms and conditions of these Standards.
108.110. Service Disconnect Switch means the electrical device owned by the
Wireless Provider which purpose is to de-energize the entire Wireless Installation,
and must meet the requirements provided in the CPS Energy Electric Service
Standards and all other applicable code requirements.
109.111. Simple Transfer means the transfer, relocation, or alteration of any
Attachment or Overlash on an existing Pole or onto a new Pole that does not require
cutting and splicing of the Communication Facility subject to such transfer,
relocation, or alteration. A Simple Transfer may include the transfer, relocation, or
alteration of a Wireless Installation that is mounted or otherwise supported by a Pole.
110.112. Single Pole Banner means a vertically installed Banner made of light weight
fabric, non-toxic material, with dimensions not to exceed 28” x 76” which may be
temporarily affixed to the side of a Pole or Streetlight Pole located on Public Right
of Way.
Slab-Mounted Equipment Cabinet means a stand-alone, weatherproof, metal
enclosure consisting of a utility metering section and a Wireless Equipment section,
which must be purchased, installed and owned by the Wireless Provider, and
approved by CPS Energy as part of the pre-certification process.
111.113. Streetlight Pole means a pole structure of a non-decorative nature owned by
CPS Energy that is not part of the electric distribution system which primary function
is to support equipment used to provide overnight streetlight service, overhead
streetlight service, or all night security light service. The term “Streetlight Pole”
includes both an Overhead Streetlight Pole and Underground Streetlight Pole. The
term “Streetlight Pole” only includes pole structures embedded in the ground and
excludes pole structures with break-away bases.
112.114. Tag means to place a distinct marker within twelve inches (12”) of a Pole on
the wires and cables, coded by number, color, or other means that will readily identify
the owner of the Attachment Mid-Sspan Installation or Wireless Installation as set
forth at Appendix K. The Tag shall be consistent with accepted communications
industry standards. Regarding Banner Attachments, all Banners and permanent
attached hardware shall include an identification Tag.
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113.115. Tagging Plan means a written plan developed by the Attaching Entity at the
request of CPS Energy to address and remedy untagged or incorrectly tagged
Attachments, Banner Attachments, Overlashings, or Wireless Installations.
114.116. Telecommunications Services means that definition provided at 47 U.S.C.
§153(46), including any revisions to that definition.
115.117. Tier 1 Revisions means revisions to the CPS Energy Pole Attachment
Standards which do not require changes in the collection of field data necessary to
prepare an Application for submission.
116.118. Tier 2 Revisions means revisions to the CPS Energy Pole Attachment
Standards which require changes in the collection of field data necessary to prepare
an Application for submission.
117.119. Transmitter means any electronic device which purpose is to generate,
amplify, and/or control, radio frequencies.
118.120. Unauthorized Attachment means any Attachment or Overlash of an
Attaching Entity (a) for which the Attaching Entity failed to obtain a Permit; or (b)
which is not in compliance with the requirements of the Permit issued for said
Attachment or Overlash. An Attachment installed by an entity that failed to execute
a Pole Attachment Agreement, or installed after the expiration or termination of such
agreement shall also be considered an Unauthorized Attachment.
119.121. Unauthorized Attachment Charge means the charge payable by an
Attaching Entity for Unauthorized Attachments as described in Appendix H.
120.122. Unauthorized Banner Attachment means any Banner Attachment (a) for
which the Banner Attacher failed to obtain a Permit, or (b) which is not in compliance
with the requirements of the issued Permit. Any Banner Attachment (a) that supports
a Banner installed by an entity that failed to execute a Banner Attachment Agreement,
or (b) installed after the expiration or termination of Banner Attachment Agreement
shall be considered an Unauthorized Banner Attachment.
121.123. Unauthorized Banner Attachment Charge means the charge payable by a
Banner Attacher for Unauthorized Banner Attachments as described in Appendix H.
122.124. Unauthorized Wireless Installation means any Wireless Installation or
Mid-Span Installation of an Attaching Entity (a) for which the Attaching Entity failed
to obtain a Permit; or (b) that is not in compliance with the requirements of the Permit
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issued for said Wireless Installation or Mid-Span Installation. A Wireless Installation
installed by an entity that failed to execute a Wireless Installation or Wireless
Addendum to supplement a Pole Attachment Agreement;Agreement, or a Mid-Span
Installation installed by an entity that failed to execute a Pole Attachment Agreement;
or by an entity after contract expiration or termination, shall also be considered an
Unauthorized Wireless Installation.Wireless Addendum, or by an entity after contract
expiration or termination shall also be considered an Unauthorized Wireless
Installation.
123.125. Unauthorized Wireless Installation Charge means the charge payable by
an Attaching Entity for Unauthorized Wireless Installation as described in Appendix
H.
124.126. Underground Streetlight Pole means a Streetlight Pole whose luminaire is
fed by underground electrical distribution facilities owned by CPS Energy.
125.127. Video Services means video programming services provided through
wireline facilities located at least in part in the pPublic Rright-of-Wway without
regard to delivery technology, including Internet protocol technology.
126.128. Wireless Addendum means an addendum to a Pole Attachment Agreement
that grants the eligible Attaching Entity a general license to submit Applications to
CPS Energy for Wireless Installations. Together with a Pole Attachment Agreement,
a Wireless Addendum grants an Attaching Entity substantially the same privileges
and obligations for the construction, operation, or use of Wireless Installations as a
standalone Wireless Installation Agreement. The Wireless Addendum may be
referred to generally in the Standards as a “Pole Attachment Contract.”
127.129. Wireless Equipment means any FCC-authorized radio equipment
components owned by a Wireless Provider used for a Wireless Installation, including
Antennas, Remote Radio Heads, Transmitters, transceivers, and related equipment of
a Wireless Installation.
128.130. Wireless Equipment Area means the space on a Pole or Overhead Streetlight
Pole comprising of the area where the following components of a pole-mounted
Wireless Installation are located: (i) Antenna Area; (ii) Wireless Equipment Cabinet;
and (iii) Backhaul Network Interface Device. For a Wireless Installation utilizing the
Pole Top Space, the Wireless Equipment Area will not include the Antenna Area.
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129.131. Wireless Equipment Cabinet means a weather-tight enclosure that houses
Wireless Equipment and electronics. Wireless Equipment Cabinets are inventoried
Wireless Installation components.
130.132. Wireless Installation means an Wireless Provider-owned installation the
components of which are mounted onto or supported by a Pole or Overhead
Streetlight Pole, in whole or in part, that sends and/or receives licensed or unlicensed
radio frequency signals, and consists of several wireless components, including but
not limited to Wireless Equipment, Wireless Equipment Cabinet or Slab-Mounted
Equipment Cabinet, and Antennas; along with support structures; riser cable; conduit;
accessory equipment; and other ancillary equipment. The term Wireless Installation
also includes a Mid-Sspan Installation suspended between two pole structures and a
DAS System that utilizes multiple pole structures.
131.133. Wireless Installation Agreement means an executed agreement between
CPS Energy and a Requestor or an executed Wireless Addendum, if applicable, that
grants a license to install Wireless Installations, that adopts and incorporates these
Standards by reference, and that incorporates the agreement of the Requestor to abide
by the terms and conditions of such agreement as well as the duties and obligations
set out in these Standards as they may be amended from time to time. A Wireless
Installation Agreement shall include additional legal protections and obligations of
the parties not specifically covered in the Standards. Throughout these Standards,
when the term “Wireless Installation Agreement” is used, it shall also include a “Pole
Attachment Agreement” coupled with a “Wireless Addendum” if appropriate. The
Wireless Installation Agreement may be referred to generally in the Standards as a
“Pole Attachment Contract.”
132.134. Wireless Installation Fee means the total annual rental payment assessed by
CPS Energy to each Attaching Entity that owns Wireless Installations determined by
multiplying the [Wireless Rate] x [total number of pole-feet occupied by an Attaching
Entity’s Wireless Installations], as described in Appendix H.
133.135. Wireless Interference means the material adverse effect of unwanted energy
due to one or a combination of emissions, radiations, or inductions upon reception in
a pre-existing radio communication system, manifested by any material performance
degradation, misinterpretation, or loss of information which could be extracted in the
absence of such unwanted energy.
134.136. Wireless Project Area means a defined urban or suburban geographical area
identified by an Attaching Entity for the deployment of one or more Wireless
Installations utilizing the same technology at each installation in order to provide, or
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enhance the provision of Wireless Service or Commercial Mobile Radio Service. A
Wireless Project Area shall consist of a defined geographic area of poor wireless
coverage within the overall service area covered by the Wireless Provider on whose
behalf the Wireless Installations are deployed, and is not considered part of a
Deployment Plan.
135.137. Wireless Provider means a CMRS Provider, a Certified Provider that holds
a State Issued Certificate of Franchising Authority, or an Infrastructure Provider
authorized to use Public Right of Way for the purpose of installing Wireless
Installations pursuant to Chapter 284 of the Texas Local Government Code.
136.138. Wireless Rate means the same annual rate as the Attachment Rate.
137.139. Wireless Service means the provision of authorized voice, video or data
services, including but not limited to Telecommunications Services, over Wireless
Installations.
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B. Registration of Entity
1. Initial Registration Information. Before executing a Pole Attachment, Banner
Attachment Agreement or Wireless Installation Agreement, a Requestor must submit a
complete an Attaching Entity Registration & Annual Reporting Form, a copy of which
is provided in Appendix A and available to download at
www.cpsenergy.com/poleattachments, to CPS Energy. The Attaching Entity
Registration & Annual Reporting Form must indicate:
a) Corporate name of the Requestor;
b) Corporate contact information;
c) Contact information for a primary liaison and an escalation list of company
personnel responsible to respond to any operational requests from CPS Energy;
d) Whether the entity holds a certificate from the Public Utility Commission of Texas
(PUCT); and
e) If the entity has been granted a franchise, license agreement, permit or ordinance
by the City of San Antonio or a suburban city within the CPS Energy service area.
f) If the Requestor is an Infrastructure Provider, identify the name and contact
information of the Infrastructure Provider Sublicensee(s) under contract with
Requestor.
The Requestor shall provide copies of the PUCT certificate and any franchise or license
agreements, permits, or ordnances with the Attaching Entity Registration & Annual
Reporting Form authorizing access to the Public Rights of Way within the CPS Energy
service area. CPS Energy shall have no obligation to execute a Pole Attachment or
Wireless Installation Agreement or approve an Application for a Permit within any part
of its service area to any Requestor that has not been granted the right to use Public Right
of Ways for the installation of such Attachments or Wireless Installations.
2. Updates to Registration Information. The Attaching Entity Registration & Annual
Reporting Form must be submitted at the time of contract execution and updated annually
thereafter by September 1st of each year or as changes in Attaching Entity’s information
warrant. The Attaching Entity has an obligation and duty to maintain the accuracy of the
information in the Attaching Entity Registration & Annual Reporting Form at all times.
CPS Energy is not obligated to contact any person not listed on the Attaching Entity
Registration & Annual Reporting Form.
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C. Execution of Pole Attachment, Banner Attachment, or Wireless Installation Agreement
Every registered Requestor must execute a Pole Attachment, Banner Attachment, or Wireless
Installation Agreement that incorporates these Standards by reference, and CPS Energy must
countersign such agreement, before the Requestor may submit an Application. Except as
otherwise set out herein, an Application must be submitted in compliance with these
Standards for every new Attachment, Banner Attachment, Overlash, or Wireless Installation,
that an Attaching Entity seeks to make to a CPS Energy Pole or Streetlight Pole, as
appropriate. CPS Energy’s Pole Attachment Application process is described in detail in
Section IV (for wire Attachments), Section V (for Wireless Installations), and Section VI
(for Banner Attachments) of these Standards.
CPS Energy may approve or deny an Application, in whole or in part, for reasons of safety,
reliability, or insufficient Capacity that cannot be resolved in a manner consistent with the
Applicable Engineering Standards; and subject to the conditions, processes, and timelines
outlined in these Standards. The uninterrupted processing of an Attaching Entity’s
Application is contingent on the timely payment of invoices for Attachments, Banner
Attachments, and Wireless Installations, and compliance with the requirements and
specifications of these Standards.
The issuance of a Permit is the only means for securing the privilege to make an Attachment,
Overlash, Wireless Installation, or Banner Attachment to any CPS Energy Pole, or Streetlight
Pole, as appropriate.
1. Separate Agreements Required for Wire Attachments, Wireless Installations, and
Banner Attachments. A wire Attachment or Mid-Span Installation may only be
attached to a Pole, or supported by a pair of Poles, respectively, pursuant to a Pole
Attachment Agreement. A Wireless Installation may be attached to a Pole or Overhead
Streetlight Pole pursuant to a Wireless Installation Agreement, or a Pole Attachment
Agreement, or Pole Attachment Agreement that has been amended and supplemented
through the execution of a Wireless Addendum. Similarly, a Banner Attachment may
only be attached to a Pole or Streetlight Pole pursuant to a Banner Attachment
Agreement. A Pole Attachment Agreement does not convey any license, claim, or rights
to attach Wireless Installations (excluding Mid-Span Installations) onto any Attachments
on CPS Energy Poles. as either a Mid-span Installation or pole-mounted installation
means. Absent a separate Wireless Installation Agreement or a Pole Attachment
Agreement that has been amended and supplemented through the execution of a Wireless
Addendum. AnyAddendum, any Wireless Installation (excluding any Mid-Span
Installation), including any Mid-span Installation, found mounted onto a Pole or
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Overhead Streetlight Pole, or clamped mid-span onto an Attaching Entity’s Messenger
cable shall be considered an Unauthorized Wireless Installation subject to Unauthorized
Wireless Installation Charges and any other sanctions specified herein.
2. Standards Applicable Regardless of Effective Agreement. Upon their effective date,
these Standards shall be applicable to all Attachments, Wireless Installations, and Banner
Attachments of an Attaching Entity whether or not the Attaching Entity is a party to a
valid and existing Pole Attachment Contract. Any Attachments, Wireless Installations,
or Banner Attachments in place at the time the corresponding Attachment Contract
expires or terminates, as well as any additional Unauthorized Attachments installed
subsequent to such expiration or termination but prior to the execution of a successor
agreement, will be subject to these Standards. Upon execution of a successor agreement,
these Standards will remain in effect and shall be incorporated into the contractual terms
in such successor agreement. This Section II.C.2, is not intended to supersede, eliminate,
or substitute any contractual protections or duties included in such successor agreement.
D. Application Submittal; No Commingling of Attachments
1. No Commingling of Attachments. When submitting an Application for a Permit, the
Attaching Entity must specify whether the Application is for a wire Attachment,
Overlash, Wireless Installation, or Banner Attachment. The comingling of different
types of facilities under one Application is strictly prohibited. In appropriate instances,
a wire Attachment Application and an accompanying Wireless Installation Application
may be submitted and considered by CPS Energy together as a single project provided
the Attaching Entity identifies these Applications as “associated” on the appropriate
Application Forms. CPS Energy will not allow Banner Attachments to be comingled
with any other type of Attachment or Wireless Installation under a single or two
“associated” Applications.
2. Number of Poles per Application or Notification. For new Attachments and/or
Overlashings, the maximum number of Poles to be considered on a single Application is
one-hundred twenty (120) Poles. For a Wireless Installations (excluding Mid-Span
Installations), a single Application shall onlymay include one (1) up to a maximum of
thirty (30) Wireless Installations locations, together with the applicable Poles and/or
Overhead Streetlight Poles, provided that the Wireless Installations isare the same or
substantially similar in design as pre-certified by CPS Energy, at each of the locations
within the identified boundaries of a Wireless Project Area. Concerning Mid-Spanapn
Installations, a single Notification may include up to five (5) Mid-Span Installations.
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Regarding an Application for Banner Attachment, the Banner Attacher may request
access to a Pole or Streetlight Pole. A single Application may include up to a maximum
of thirty (30) Single Pole Banner locations, and a maximum of thirty (30) Double Pole
Banner locations.
3. Authorization Process Required. No Attachingperson or Eentity is authorized to install
an Attachment, Overlash, Wireless Installation, Mid-Span Installation, or Banner
Attachment on to a Pole or Streetlight Pole, pursuant to these Standards, without first
executing the appropriate Pole Attachment Contract, submitting a complete Application
or Notification, as appropriate, and securing and receiving an appropriate Permit.
Concerning a temporary Banner, the Banner Attacher shall submit to CPS Energy at least
five (5) business days prior to the installation an electronic notification of the type of
Banner installation requested, along with the appropriate municipal permit authorizing
the installation in the Public Right of Way, and any other information requested by CPS
Energy. Upon review, CPS Energy shall approve the temporary Banner installation no
later than five (5) business days from receipt. Failure to timely approve the Banner
installation shall be considered as authorization to proceed with the installation.
E. Termination of Permit
1. Automatic Termination of Permit. Any Permit issued pursuant to these Standards shall
automatically terminate when the Attaching Entity ceases to have authority to construct
and operate Communications Facilities or Wireless Installations, or engage in the
installation and display of Banner Attachments on public or private property, as
appropriate, including federal property, at the location of the particular Pole or Streetlight
Pole, as appropriate, covered by the Permit.
2. Surrender of Permit. An Attaching Entity may at any time surrender any Permit and
remove the corresponding Attachment, Wireless Installation, or Banner Attachment from
the affected pole structure provided, however, that before commencing any such removal,
the Attaching Entity must provide a twenty-one (21) calendar days advance written notice
and sketch of the facilities to be removed to CPS Energy, including the name of the
Attaching Entity or other qualified contractor performing such work and the date and
time during which such work will be undertaken and completed. All such work is subject
to the insurance requirements of the corresponding Pole Attachment Agreement,
Wireless Installation Agreement, or Banner Attachment Agreement. No refund of any
fees or costs paid to CPS Energy will be made upon removal.
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If an Attaching Entity surrenders such Permit pursuant to the provisions of this Section
II.E.2, but fails to remove its Attachment, Wireless Installation, or Banner Attachment
from CPS Energy’s Facilities within sixty (60) calendar days thereafter, CPS Energy
shall have the right to remove the Attachment, Wireless Installation, or Banner
Attachment at the Attaching Entity’s expense.
F. Annual Reporting Requirements
Following initial submission of the Attaching Entity Registration & Annual Reporting Form
pursuant to Section II.B.2, Attaching Entities must provide annual updates thereafter.
Concurrently with submitting the updated Attaching Entity Registration & Annual Reporting
Form, the Attaching Entity shall report the following to CPS Energy:
1. List of Installations. The Attaching Entity shall provide a list of specific Poles and/or
Streetlight Poles (by CPS Energy Pole number, if available) on which the Attaching
Entity has installed, during the previous twelve (12) month reporting period new
Attachments, Overlashings, Wireless Installations, or Banner Attachments including
risers and Service Drops, or any other facility for which no Permit was required per
Section IV.B.2.b.
2. List of Non-Functional Attachments. The Attaching Entity shall provide a list of all
Attachments, Overlashings, Wireless Installations, Banner Attachments, or other
equipment that have either become non-functional, surrendered, or for which the
Attaching Entity is no longer paying the annual Attachment Connection Fee, Wireless
Installation Fee, or Banner Attachment Connection Fee during the previous twelve (12)
month reporting period. The report shall identify the specific Pole or Streetlight Pole (by
CPS Energy Pole number, if available) on which the nonfunctional Attachment,
Overlash, Wireless Installation, Banner Attachment, or other equipment is located and
provide a description of the nonfunctional equipment.
3. Removed Equipment. The Attaching Entity shall provide a list of all Attachments,
Overlashings, Wireless Installations, Banner Attachment, or other equipment removed
(and not replaced by substantially similar equipment) from specific Poles or Streetlight
Pole (by CPS Energy Pole number, if available) during the previous twelve (12) month
reporting period. The report shall identify the Pole from which the equipment was
removed, a description of the removed equipment, and indicate the approximate date of
removal. This requirement does not apply where the Attaching Entity surrenders a Permit
pursuant to Section II.E.2.
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4. Emergency Contact. The Attaching Entity shall maintain current at all times the
emergency contact information required by the applicable Pole Attachment Contract,
along with contact information for the Network Operations Center, if applicable.
5. Failure to Report. Failure of an Attaching Entity to provide CPS Energy the updated
Attaching Entity Registration & Annual Reporting Form required by this Section II.F
within forty-five (45) calendar days following issuance of written notice of the failure to
comply timely with the annual reporting requirements of this section shall result in CPS
Energy suspending all work on the Attaching Entity’s pending Applications or which
may be submitted after the suspension date. Within three (3) business days of CPS
Energy receiving the updated Attaching Entity Registration & Annual Reporting Form,
CPS Energy shall resume processing the Attaching Entity’s Applications in the order that
they were initially received by CPS Energy.
6. Right to Audit. CPS Energy reserves the right to perform an audit on any annual
reporting required by this Section II.F to validate the information provided. Failure to
provide accurate reporting will subject the Attaching Entity to the provisions provided in
Section II.F.5 above.
G. Notices
1. Notice of Revisions to the Pole Attachment Standards. CPS Energy shall publish any
proposed revisions to these Standards on the CPS Energy public website,
www.cpsenergy.com/poleattachments. CPS Energy shall also send electronic notice to
the primary contact and email address for each Attaching Entity provided in the
Attaching Entity Registration & Annual Reporting Form, as described in Section II.B.
CPS Energy is under no obligation to contact anyone other than the primary contact
provided with regard to notice under this Section II.G. CPS Energy shall enforce and an
Attaching Entity shall adhere to the revised Standards for new Applications on their
effective date. Notwithstanding the previous sentence, no revisions to the Applicable
Engineering Standards shall be retroactive to existing permitted Attachments,
Overlashings, Wireless Installations, or Banner Attachments unless required by city,
county, state, or federal law or if the Attachment, Overlash, Wireless Installation, or
Banner Attachment is modified after the effective date of the revised Standards. If an
Attachment, Overlash, Wireless Installation, or Banner Attachment is modified,
including without limitation moved, upgraded, repaired, replaced, or Overlashed (in the
case of an existing Attachment), the Attachment, Overlash, Wireless Installation, or
Banner Attachment shall immediately become subject to the Standards then in effect.
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Any amendment to the Standards shall apply to an Application submitted on or after the
amendment becomes effective as per the schedule below:
a) Tier 1 Revisions. CPS Energy shall publish Tier 1 Revisions forty-five (45) calendar
days prior to their effective date.
b) Tier 2 Revisions. CPS Energy shall publish Tier 2 Revisions ninety (90) calendar
days prior to their effective date.
CPS Energy will conduct quarterly workshops for the benefit of all Attaching Entities
during the months of February, May, August, and November of each year. During
these workshops CPS Energy and the Attaching Entities may discuss overall
implementation of the Standards, including proposals for making amendments to
improve operations, procedures, and/or administration of CPS Energy’s Pole
Attachment Program. All proposals for either Tier 1 or Tier 2 Revisions to the
Standards proposed by CPS Energy will be discussed at a quarterly workshop prior
to publication.
2. Process to Request Revisions to the Standards. An Attaching Entity may formally
request a revision to the Standards by:
a) Completing the CPS Energy Pole Attachment Standards Revision Request (PASRR)
form, a copy of which is provided in Appendix B and available for download at the
CPS Energy Pole Attachment website, www.cpsenergy.com/poleattachments;
b) Submitting the completed PASRR to CPS Energy;
c) CPS Energy shall review a properly completed PASRR form received and will
publish the PASRR on the Pole Attachment webpage for stakeholder comments for
a minimum of thirty (30) calendar days.
d) Attaching Entities and other interested stakeholders may submit comments, including
draft substitute language within the thirty (30) calendar day comment period.
Comments are to be submitted to CPS Energy using the PASRR Comment form, a
copy provided in Appendix B and available for download on the CPS Energy Pole
Attachment website, www.cpsenergy.com/poleattachments;
e) Within thirty (30) calendar days following the end of the comment period, CPS
Energy will publish its rationale and decision to accept, modify, or reject the PASRR
either in-part or in-whole. CPS Energy will discuss its decision regarding the
PASRR at the next scheduled quarterly workshop as described in Section II.G.1. CPS
Energy reserves the right to extend the time period for stakeholder comments or the
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period to respond to stakeholder comments. In the event of such extension, CPS
Energy will notify stakeholders by posting such notice of extension on the Pole
Attachment website, www.cpsenergy.com/poleattachments.
H. Scope of Standards
1. Grant of Permit. The issuance of a Permit by CPS Energy authorizing the placement
of an Attachment, Overlash, Wireless Installation, Mid-Span Installation or Banner
Attachment on a pole structure, or supported by a pair of Poles, pursuant to the provisions
of these Standards, will operate to grant the Attaching Entity a revocable, nonexclusive
license to install and maintain the Attachment, Overlash, Wireless Installation, Mid-Span
Installation,or Banner Attachment on a specific pole structure, or set of poles in the case
of Mid-span Installation. The grant of a Permit entitles the Attaching Entity to the quiet
enjoyment of its Attachments, Overlash, Wireless Installation, Mid-Span Installation or
Banner Attachment subject to all requirements of these Standards, including the
procedures for the transfer or relocation of such Attachment, Overlash, Wireless
Installation, Mid-Span Installation or Banner Attachment.
2. Parties Duties and Obligations under Standards. These Standards set out the duties
and obligations of CPS Energy and an Attaching Entity regarding the processing of an
Application, issuance of a Permit, compliance with Applicable Engineering Standards,
and administration of an Attachment, Overlashing, Wireless Installation, or Banner
Attachment on a pole structure, as appropriate, during the entire lifecycle of the
Attachment, Overlashing, Wireless Installation, or Banner Attachment.
3. Permit Issuance Conditions. CPS Energy will issue a Permit to an Attaching Entity
when there is sufficient Capacity to accommodate the requested Attachment, Wireless
Installation, or Banner Attachment or when pole loading conditions would not prohibit
an Overlashing, and the corresponding Application complies with all Applicable
Engineering Standards. CPS Energy may deny a Permit on a nondiscriminatory basis
where there is insufficient Capacity or for reasons of safety, reliability, or as set forth in
the Applicable Engineering Standards. CPS Energy shall provide the specific
nondiscriminatory reasons for denial of an Application in writing with the rejected
Application.
4. No Interest in Property. No use, however lengthy, of any CPS Energy Facilities, and
no payment of any fees or charges required under these Standards, shall create or vest in
an Attaching Entity any easement or other ownership or property right of any nature in
any portion of such CPS Energy Facilities.
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5. Non-Exclusivity. A Permit granted to an Attaching Entity under these Standards is non-
exclusive and shall have no effect or take legal precedence over any Permit, rights, or
other privileges granted by CPS Energy to any other entity to use a CPS Energy Pole or
Streetlight Pole.
a) No Attaching Entity is entitled to reserve or schedule space on any Pole or Streetlight
Pole, other than pole space for which a Permit has been granted.
b) An approved Permit is subject at all times to CPS Energy’s right to provide core
electric utility services, including the provision of all internal communications
essential to the proper operations of such core electric utility services.
c) The issuance of a Permit by CPS Energy grants only a license and no possessory
interest to a specific Pole or Streetlight Pole, or to any space on such pole.
6. CPS Energy’s Rights over Poles. The granting of a Permit does not in any way limit
CPS Energy’s right to locate, install, operate, maintain, relocate, or remove its Poles or
Streetlight Poles in the manner and at the time that will best enable it to fulfill its core
electric and customer service requirements. CPS Energy reserves to itself the right to
maintain CPS Energy Poles, Streetlight Poles, and other CPS Energy Facilities and to
operate its facilities thereon in such manner as shall enable CPS Energy to fulfill its own
electric service, lighting, maintenance, and customer service obligations and
requirements.
7. Restoration of CPS Energy Service. CPS Energy’s service restoration requirements
shall take precedence over any and all work operations of any Attaching Entity on CPS
Energy’s Poles and Streetlight Poles. CPS Energy may relocate, replace, or remove an
Attaching Entity’s Attachments, Overlashings, Wireless Installations, or Banner
Attachments, transfer them to substituted poles or perform any other work in connection
with such Attachments, Overlashings, Wireless Installations, or Banner Attachments that
CPS Energy deems necessary in order to safely and efficiently restore electrical service.
CPS Energy shall not be liable to an Attaching Entity for any actions CPS Energy takes
pursuant to this Section II.J.7. The affected Attaching Entity shall reimburse CPS Energy
for the expenses that CPS Energy incurs relating to such work within forty-five (45)
calendar days of the date CPS Energy issues an invoice for such work.
8. Permitted Uses. All Attaching Entities shall be permitted to use an approved
Attachment or Overlash only for the purpose of providing Communications Services.
Wireless Installations shall only be used for the provision of Wireless Services. Banner
Attachments shall only be used to provide Banner Advertisement services. An Attaching
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Entity is not permitted to install an Attachment, Overlash, Wireless Installation, or
Banner Attachment on behalf of any other party; sublease an Attachment, Overlash, or
Wireless Installation to any other party; or install an Overlash, Wireless Installation or
Banner Attachments belonging to a third-party, regardless of whether the third-party is
an Affiliate of an Attaching Entity, unless both the Attaching Entity and the third party
have registered and executed an appropriate Pole Attachment Contract with CPS Energy.
Specifically, Infrastructure Providers are required to identify their Infrastructure Provider
Sublicensees in compliance with Section II.B.1 and such Ssublicensees shall be required
to execute the Infrastructure Provider Sublicensee Wireless License Agreement. Any
use of an Attachment, Overlashing, Wireless Installation, or Banner Attachment other
than as specified herein, shall be considered an Unauthorized Attachment, Unauthorized
Wireless Installation, or Unauthorized Banner Attachment subjecting the non-compliant
Attaching Entity to enforcement action by CPS Energy, including:
a) Suspension of the processing of any further Applications submitted by the Attaching
Entity pending resolution of the unauthorized use;
b) Revocation of previously granted Permits; and
c) Contractual claims under the Pole Attachment, Wireless Installation Agreement, or
Banner Attachment Agreement, as appropriate.
9. Expansion of Capacity. CPS Energy will expand Pole Capacity, at an Attaching Entity’s
expense, when necessary to accommodate an additional Attachment, Banner Attachment,
or Wireless Installation approved pursuant to the issuance of a Permit, and when
consistent with local governmental land use requirements of general applicability and the
Applicable Engineering Standards. Notwithstanding the foregoing sentence, CPS
Energy is under no obligation to install, retain, extend, or maintain any Pole or Streetlight
Pole for the benefit of an Attaching Entity when such pole or system of poles is not
needed for CPS Energy’s core electric or customer service requirements.
10. Reserved Capacity. At the time that CPS Energy receives an Application, CPS Energy,
to the extent information is known at that time, may communicate to the requesting
Attaching Entity, CPS Energy’s obligation to reserve space on a Pole as Reserved
Capacity for its own future use in accordance with a bona fide electric system expansion
or improvement plan that reasonably and specifically projects a need for that space for
the provision of its core electric utility or lighting services, including any and all
associated internal communications. Reserved Capacity shall be made available for use
by an Attaching Entity consistent with these Standards and this Section II.H.10 until CPS
Energy has a need for such Reserved Capacity.
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a) CPS Energy may reclaim the Reserved Capacity if required for CPS Energy’s use at
such time by giving the Attaching Entity at least ninety (90) calendar days’ advance
notice. CPS Energy shall give the Attaching Entity the option to remove its
Attachment, Wireless Installation, or Banner Attachment from the affected Pole or to
pay for the cost of any Make-Ready Work needed to expand Capacity so that the
Attaching Entity may maintain its Attachment. Wireless Installation, or Banner
Attachment on the affected Pole as provided in Section II.H.10.b below.
b) CPS Energy may require an Attaching Entity to remove its Attachment, Wireless
Installation, or Banner Attachment from the affected Pole if the Attaching Entity does
not opt to pay for the cost of Make-Ready Work needed to expand Capacity within
forty-five (45) calendar days of CPS Energy issuing notice that CPS Energy requires
use of the Reserved Capacity. CPS Energy may remove the Attachment, Wireless
Installation, or Banner Attachment if the Attaching Entity fails to remove it from the
affected Pole within ninety (90) calendar days of CPS Energy issuing notice that CPS
Energy requires use of the Reserved Capacity. CPS Energy shall invoice the affected
Attaching Entity for the actual cost that CPS Energy incurs for such removal, and the
Attaching Entity shall pay such invoice no later than forty-five (45) calendar days
following issuance of invoice.
c) If CPS Energy reclaims Reserved Capacity for which an Attaching Entity has
received a Permit and paid for Make-Ready Work, where the Make-Ready Work
consisted of relocating CPS Energy’s Neutral on the existing Pole to allow the
Attaching Entity’s use of Reserved Capacity, but the installation of the Attachment,
Wireless Installation, or Banner Attachment is not complete, CPS Energy shall refund
all payments made by the Attaching Entity for the applicable Application Fee and
Make-Ready Work on the affected pole.
11. Authorization for Use of One-Touch Transfer Process. All Attaching Entities with
Attachments, Overlashings, Wireless Installation, or Banner Attachments on any CPS
Energy pole structures shall be subject to a Simple Transfer and/or rearrangement of their
Attachments, Overlashings, Wireless Installations, or Banner Attachments pursuant to
the One-Touch Transfer Process described in Section IV.B.5 and Section V.B.5, provided
that any such transfer or rearrangement is consistent with these Standards including all
Applicable Engineering Standards. An Attaching Entity is entitled to utilize the One-
Touch Transfer Process in installing its Attachments, Overlashings, Wireless
Installations, or Banner Attachments provided that the requirements of Section IV.B.5,
Section IV.B.6, Section V.B.5, and Section V.B.6 are followed.
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I. Fees and Charges
1. General. All Attaching Entities shall be subject to the CPS Energy Schedule of Pole
Attachment Rates, Fees, and Charges as specified in Appendix H, as may be amended,
and shall comply with the terms and conditions specified herein.
a) Wherever CPS Energy is required to perform any work related to the Pole Attachment
Program on behalf of an Attaching Entity, CPS Energy, at its sole discretion, may
utilize its employees or contractors, or any combination of the two, to perform such
work. Invoices submitted directly to an Attaching Entity from a CPS Energy
contractor shall be treated as if the invoice was issued from CPS Energy pursuant to
these Standards.
b) Wherever an Attaching Entity is required to pay for such work done or contracted by
CPS Energy, the charge for such work shall include all reasonable material, labor,
travel, engineering, administrative, and applicable overhead costs, other than those
costs compensated by payment of the applicable Application Fee, or the annual
Attachment Connection Fee, Wireless Installation Fee, or Banner Attachment
Connection Fee.
c) No rates, fees, and/or charges specified in Appendix H shall be refunded on account
of any surrender of a Permit.
d) All Attaching Entities shall pay CPS Energy or its contractor in accordance with the
terms of this Section II.I and Appendix H.
e) If CPS Energy or its contractor does not receive payment from an Attaching Entity
for any amounts owed within forty-five (45) calendar days after it becomes due, the
Attaching Entity shall pay in addition to the initial amount, interest to CPS Energy at
the rate of one and 17/100 Percent (1.17%) simple interest per month on the amount
due beginning from the first of the month following the forty-five (45) calendar days
until the payment is made. Should payment not be received within sixty (60) days
following the due date, CPS Energy shall suspend the processing of the Attaching
Entity’s Applications until payment is paid in full.
f) Excluding the annual Attachment Connection Fee, Wireless Installation Fee, and
Banner Attachment Connection Fee, should an Attaching Entity wish to dispute an
invoice from either CPS Energy or its contractors; the Attaching Entity shall within
fifteen (15) days of receipt of the invoice provide CPS Energy written notice of its
intention to dispute the invoice. This notice shall include:
(i) a copy of the invoice being disputed;
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(ii) a detailed description of the disputed amounts;
(iii) all documentation to support the Attaching Entity’s claim of dispute; and
(iv) any legal basis for the claim of dispute.
Within ten (10) days of receipt of the written notice of dispute, CPS Energy will
arrange a meeting or teleconference with the Attaching Entity to begin discussions
regarding the dispute in accordance with the conflict resolution provisions provided
in Section II.L.1.
The invocation of a dispute by an Attaching Entity does not relieve the Attaching
Entity from timely payment of the invoice pursuant to Section II.I.1.h. Should CPS
Energy and the Attaching Entity reach agreement on an amount less than the invoiced
amount under dispute and paid under protest or dispute, CPS Energy, or its contractor,
shall either reimburse or provide future credit to the Attaching Entity in accordance
with the agreement of the parties provisions.
g) Nonpayment of a non-disputed amount invoiced by CPS Energy or its contractor and
due beyond ninety (90) days shall subject an Attaching Entity to escalating
enforcement action, including but not limited to:
(i) Suspension of the processing of any further Applications submitted by the non-
compliant Attaching Entity pending receipt of payment;
(ii) Potential contractual claims; and
(iii) Termination of the Pole Attachment, Wireless Installation Agreement, or
Banner Attachments Agreement, as appropriate.
h) If an Attaching Entity pays any amount under protest or dispute, such Attaching
Entity shall make full payment consistent with the timeframe required by these
Standards and shall designate payment as “PAID UNDER PROTEST.” Failure to
contest or otherwise dispute an invoice within sixty (60) calendar days of receipt shall
be deemed to be acceptance by the Attaching Entity.
i) Failure to pay an invoice for the annual Attachment Connection Fee, Wireless
Installation Fee, or Banner Attachment Connection Fee in full based on any allegation
that CPS Energy has improperly applied or calculated the Attachment Rate, Wireless
Rate, or Banner Attachment Rate shall not constitute a legitimate basis for disputing
any invoice (other than arithmetic errors that should be brought to CPS Energy’s
immediate attention). The proper forum for making such allegations is a regulatory
agency or court of competent jurisdiction.
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2. Application Fee5 and Make-Ready Engineering Review.
a) Wireless Providers and Banner Attachers are required to pay an Application Fee per
Wireless Installation or Banner Attachment, respectively, to compensate CPS Energy
for the cost of administrative and other work required to manage the Application
process not directly reimbursed in Make-Ready Work charges or otherwise covered
by the annual Wireless Installation Fees, or Banner Attachment Connection Fee. The
appropriate Application Fee, set forth in Appendix H, shall be paid by credit card,
electric transfer, or other certified funds transaction. Any Application submitted for
CPS Energy’s consideration without payment of the non-refundable Application Fee
shall be rejected and considered incomplete. An Attaching Entity submitting an
Application for a wire Attachment, or Wireless Installation, or a Notification for a
Mid-Span Installation, shall not be assessed an Application Fee. as compensation for
such fee is included in the annual Attachment Connection Fee.
b) An Attaching Entity shall reimburse CPS Energy or its contractor for its actual costs
to complete the Application process. Such costs constitute Make-Ready Engineering
services, including back-office engineering services and field inspection work
described in Sections IV, V, and VI. CPS Energy or its contractor shall invoice each
Attaching Entity for the work completed in processing the Attaching Entity’s
Applications on a monthly basis. If the Attaching Entity fails to pay the Make-Ready
Engineering costs within forty-five (45) calendar days following issuance of the
invoice; CPS Energy will (i) suspend processing of the Attaching Entity’s pending
Applications and any subsequent Applications; and/or (ii) revoke the Permits issued
under the Applications for which Make-Ready Engineering review charges have not
been paid. Upon full payment, CPS Energy will resume processing and restore any
Permits which may have been revoked under this Section II.I.2.b.
c) In the event that an Application is submitted by an Attaching Entity and then is
subsequently cancelled, the Attaching Entity shall forfeit the Application Fee
submitted with the cancelled Application. The Attaching Entity shall also reimburse
CPS Energy or its contractor for the costs incurred up to the date of cancellation.
Should CPS Energy cancel the Application pursuant to its rights under these
Standards, CPS Energy will reimburse the Application Fee to the Attaching Entity.
3. Advance Payment for Make-Ready Electrical Construction. Where Make-Ready
Electrical Construction is required, the Attaching Entity is required to make advance
5 CPS Energy discontinued the requirement of an Application Fee on wire Attachments effective on January 1, 2017.
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payment for the Make-Ready Electrical Construction pursuant to Section IV.B.3.b,
Section IV.B.4.a, and Section VI.B.4. All required Make-Ready Electrical Construction
must be completed before an Attaching Entity shall install any Attachment, Overlashing,
Wireless Installation, or Banner Attachment. CPS Energy shall provide an invoice and
request authorization for the Make-Ready Electrical Construction by submitting to the
Attaching Entity the completed CPS Energy Authorization for Make-Ready Work form,
provided in Appendix B. The estimate provided in the CPS Energy Authorization for
Make-Ready Work form shall be valid for fifteen (15) days of issuance. Should the
Attaching Entity not indicate its acceptance within the fifteen (15) day time-frame, the
Application shall be deemed cancelled. If approved by the Attaching Entity, the
Attaching Entity shall pay CPS Energy pursuant to the terms of CPS Energy
Authorization for Make-Ready Work and Section II.I.1. CPS Energy will not schedule
or release to construction any Make-Ready Electrical Construction work on behalf of an
Attaching Entity until the advance payment is received in full by CPS Energy.
a) As provided in this Section II.I.3, CPS Energy will require advance payment of
estimated expenses for Make-Ready Electrical Construction. CPS Energy shall
perform a true up of costs for work orders closed upon request, and the following will
apply:
(i) To the extent that the actual costs of the work order exceeds the advance
payments of estimated expenses, the Attaching Entity shall pay CPS Energy for
the net difference in costs; or
(ii) To the extent that the actual costs of the work order is less than estimated costs,
CPS Energy will refund to the Attaching Entity the net difference in costs.
(iii) In either event identified in Section II.I.3.a.i or Section II.I.3.a.ii above, CPS
Energy shall either invoice or refund the appropriate costs to the Attaching
Entity within sixty (60) days following the close of each work order pursuant
to this Section II.I.3.a.
b) For any actual costs incurred by CPS Energy that are not reflected in the work order
costs for any reason, an estimated cost will be determined by CPS Energy and added
to the actual work order costs in order to account for these costs during the true up
process.
4. Annual Attachment Connection Fee. CPS Energy shall invoice the annual Attachment
Connection Fee to each Attaching Entity having permitted wire Attachments no later than
December 31st of each year. The invoice shall set forth the total number of pole feet
utilized by Attachments on CPS Energy Poles foron which the Attaching Entity was
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issued and/or holds corresponding Permits for Attachments has submitted a Pole
Attachment Application as of December 1st of the then-current rental year multiplied by
the Attachment Rate. The Attaching Entity shall pay the invoice for the Attachment
Connection Fee as specified in Section II.I.1. Failure to make timely payment of invoice
in full will result in the suspension of processing any further Applications for
Attachments submitted by the Attaching Entity pending receipt of payment.
a) The Attachment Rate shall be calculated by CPS Energy on an annual basis pursuant
to applicable laws and regulations.
b) CPS Energy will make available on its Pole Attachment webpage,
www.cpsenergy.com/poleattachments, relevant information and inputs required for
calculating the Attachment Rate.
5. Annual Wireless Installation Fee. CPS Energy shall invoice the annual Wireless
Installation Fee to each Wireless Provider having permitted Wireless Installations no
later than December 31st of each year. The invoice shall set forth the total number of
Wireless Installations and pole feet utilized for which the Wireless Provider was issued
corresponding Permitshas submitted a Pole Attachment Application as of December 1st
of the then current year multiplied by the Wireless Rate. The Wireless Provider shall pay
the annual invoice for the Wireless Installation Fee as specified in Section II.1.1. Failure
to make timely payment of the invoice in full will result in the suspension of processing
any further Applications for Wireless Installations submitted by the Wireless Provider
pending receipt of payment.
a) The Wireless Rate shall be the same as the Attachment Rate, which will be calculated
by CPS Energy on an annual basis and shall be applied on per-foot-basis in
accordance with Chapter 284 of the Texas Local Government Code.
6. Annual Banner Attachment Connection Fee. CPS Energy shall invoice the annual
Banner Attachment Connection Fee to each Banner Attacher having permitted Banner
Attachments no later than December 31st of each year. The invoice shall set forth the
total number of Banner Attachments and pole feet utilized for which the Banner Attacher
was issued corresponding Permits as of December 1st of the then current year multiplied
by the Banner Attachment Rate. The Banner Attacher shall pay the annual invoice for
the Banner Attachment Connection Fee as specified in Section II.1.2. Failure to make
timely payment of the invoice in full will result in the suspension of processing any
further Applications for Banner Attachments submitted by the Banner Attacher pending
receipt of payment.
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a) The Banner Attachment Rate shall be the same as the Attachment Rate, which will
be calculated by CPS Energy on an annual basis and shall apply to every foot of pole
space reserved by the installation of hardware for the display of Banners.
7. Unauthorized Charges. The installation of Unauthorized Attachments, Unauthorized
Wireless Installations, or Unauthorized Banner Attachments poses an increased risk to
CPS Energy personnel, the public, and legitimate Attachments, Overlashings, Wireless
Installations, and Banner Attachments of other Attaching Entities. CPS Energy shall
issue a Notice of Unauthorized Attachments, Unauthorized Wireless Installations, or
Unauthorized Banner Attachments a copy of which is provided in Appendix B, promptly
upon discovery to the Attaching Entity that owns such Attachments, Wireless
Installations, or Banner Attachments pursuant to Section III.E. Such notice shall include
the specific location of the Unauthorized Attachment, Wireless Installation, or Banner
Attachment (including CPS Energy Pole number).
a) An Attaching Entity may dispute CPS Energy’s determination by providing the
Attachment’s, Wireless Installation’s, or Banner Attachment’s Permit or approved
Application from CPS Energy within forty-five (45) calendar days of CPS Energy’s
issuance of such notice, if available.
b) CPS Energy will invoice for any Unauthorized Attachment, Unauthorized Wireless
Installation, or Unauthorized Banner Attachment identified by the terms and
conditions of this Section II.I.7, Section III.E, and Appendix H. Any Unauthorized
Attachment Charges, Unauthorized Wireless Installation Charges, or Unauthorized
Banner Attachment Charges shall be paid within forty-five (45) calendar days upon
issuance of invoice.
c) If the Attaching Entity, Wireless Installation, or Banner Attachment owner or
operator fails to pay the Unauthorized Attachment Charges, Unauthorized Wireless
Installation Charges, or Unauthorized Banner Attachment Charges within forty-five
(45) calendar days following issuance of the invoice, CPS Energy shall thereon
immediately discontinue the processing of any pending and subsequent Applications
until the invoice is paid in full, and may pursue such other and further enforcement
remedies as it may have available.
8. Other. CPS Energy may invoice other fees or penalties, described in Appendix H,
pursuant to the Pole Attachment, Wireless Installation Agreement, or Banner Attachment
Agreement, and these Standards.
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J. Claims
1. Claims for Damages to CPS Energy Facilities.
a) The CPS Energy Claims Department shall be responsible for investigating and
resolving claims for damages to CPS Energy Facilities caused by a third-party,
including an Attaching Entity, or its contractors, subcontractors, and agents.
b) An Attaching Entity shall be responsible for immediately notifying CPS Energy of
any damages to CPS Energy Facilities resulting from the Attaching Entity’s
construction activities, including the activities of its contractors, subcontractors, or
agents.
c) In the event CPS Energy Facilities are damaged by an Attaching Entity, or its
contractors, subcontractors, or agents, the CPS Energy Claims Department will
tender to the Attaching Entity at fault a third-party claim for damages.
d) The Attaching Entity is responsible for making CPS Energy whole and for
reimbursing all third-party claims associated with damages to CPS Energy Facilities
resulting from the installation, operation, maintenance, transfer, relocation, removal,
failure, or forceful detachment of an Attachment, Overlash, Wireless Installation, or
Banner Attachment whether caused by the Attaching Entity, its contractors,
subcontractors, and agents, or by any unaffiliated third-party.
2. Upon Receipt of Claim.
a) Upon receiving notification of damages to CPS Energy Facilities, whether by the
Attaching Entity or from another source, a claims file will be opened and a CPS
Energy claims representative will be assigned to the file. All CPS Energy internal
claims representatives are licensed by the Texas Department of Insurance.
b) The Attaching Entity will be timely notified of the claim for damages to CPS Energy
Facilities and will be advised that an internal investigation has commenced, and will
be provided with a preliminary assessment of the damages to CPS Energy Facilities.
c) An internal investigation will be completed by CPS Energy to determine liability for
all claims for damages to CPS Energy Facilities. Utilizing industry standard claims
software to create a record of the claims process, the assigned adjuster will investigate
the claim and gather relevant facts and documentation. All of the gathered
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information will be compiled by the licensed adjuster and analyzed to determine
liability and the total amount of damages.
d) Once a determination of liability is made regarding the claims for damage to CPS
Energy Facilities, a claims representative will notify the Attaching Entity in writing
and provide a Collection Notice Letter stating the amount of damages owed to CPS
Energy, and the Attaching Entity will have an opportunity to respond.
3. Dispute of Claim.
a) In the event liability is disputed for a claim of damages to CPS Energy Facilities, the
Attaching Entity must submit a Notice of Dispute Form, a copy of which is provided
as Appendix C, to the CPS Energy Claims Department within five (5) business days
of receiving CPS Energy’s tender explaining the reason for the disputing liability and
providing documentary support for the dispute. Dispute of a claim shall not be
capricious nor will assumption of responsibility be unreasonably withheld.
b) An Attaching Entity may conduct its own independent investigation of any claims
for damage to CPS Energy Facilities. CPS Energy shall cooperate with the Attaching
Entity’s claims investigator. CPS Energy shall consider the findings of the Attaching
Entity’s investigation provided that the investigation is completed within forty-five
(45) calendar days of the Attaching Entity submitting to CPS Energy a Notice of
Dispute Form.
c) The CPS Energy Claims Department may assign the dispute to an internal
independent review panel which will provide a de novo review of the claim file
including, the Notice of Dispute Form, and any supporting documentation submitted
by the Attaching Entity. CPS Energy will notify the Attaching Entity of the final
determination of liability within thirty (30) calendar days.
4. Payment of Claims.
a) In the event the final determination is one of liability on the part of the Attaching
Entity, CPS Energy will send a Collections Notice Letter. Upon receipt of the
Collections Notice Letter, the Attaching Entity must remit payment with twenty (20)
calendar days to the following address:
CPS Energy Claims Department
Mail Drop 110902
PO Box 1771
San Antonio, Texas 78296
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b) The correspondence accompanying payment must include the CPS Energy claims
number associated with the file.
5. Failure to Pay Claims.
a) Failure to timely pay a non-disputed claim or otherwise follow these claim procedures
shall constitute violation of these Standards and will result in the suspension of any
existing Applications and rejection of any future Applications submitted by the
Attaching Entity until such time as the claim has been satisfied and closed.
b) If a non-disputed payment is not timely received, CPS Energy will seek
reimbursement under the Attaching Entity’s performance bond.
c) CPS Energy reserves the right to refer collection on any unpaid outstanding claims
to a collections agency and/or legal counsel.
K. Compliance with Pole Attachment Standards & CPS Energy Enforcement
1. Expectation of Compliance. Pursuant to a Pole Attachment Agreement, Wireless
Installation Agreement, or Banner Attachment Agreement, as appropriate; each
Attaching Entity shall fully comply with the terms and conditions set forth in these
Standards as a condition to receive a Permit from CPS Energy.
2. Enforcement of Standards. Pursuant to either the Pole Attachment, Wireless
Installation Agreement, or Banner Attachment Agreement, as appropriate; CPS Energy
reserves all rights available to CPS Energy under these Standards and such agreements
to enforce compliance with these Standards in a non-discriminatory manner by all
Attaching Entities. In the absence of an agreement, for any reason, CPS Energy will
enforce these Standards in a non-discriminatory manner with the understanding that these
Standards do not grant any rights to any person, public entity, or private company or
corporation that is not subject to an applicable Pole Attachment Contract.
3. Safety Violations & Safety Violation Assessment Charge.
a) If during an Inspection or otherwise, CPS Energy determines that one or more of an
Attaching Entity’s Attachments, Wireless Installations, or Banner Attachments, or
any part thereof, are installed, used, or maintained in such a manner as to create one
or more Safety Violations; CPS Energy shall promptly notify the Attaching Entity in
accordance with the provisions of Section II.B.2 by issuing a Notice of Safety
Violation, a copy of which is provided in Appendix B. Attaching Entity shall correct
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the Safety Violation(s) as soon as possible, but no later than five (5) calendar days
from CPS Energy’s issuance of such notice.
If following CPS Energy’s verification the Safety Violation has not been cured within
the five (5) calendar day period:
(i) CPS Energy may correct said conditions. CPS Energy will attempt to notify the
non-compliant Attaching Entity in writing prior to performing such work
whenever practicable. Should CPS Energy determine the Safety Violation poses
an Emergency, interferes with the performance of CPS Energy’s service
obligations, or poses an immediate threat to the physical integrity of CPS Energy
Facilities; CPS Energy may perform such work and/or take such action as it
deems necessary without first giving written notice to the Attaching Entity. As
soon as practicable thereafter, CPS Energy will advise the Attaching Entity of the
work performed or the action taken. The Attaching Entity shall be responsible
for all costs incurred by CPS Energy in taking action pursuant to this Section II.K.
CPS Energy will facilitate the resolution of responsibility for violations in the
event that multiple Attaching Entities are on the same Pole.
(ii) Pursuant to Section II.K.3.a, CPS Energy will impose a ten percent (10%)
surcharge on its costs of conducting any work to correct or remedy a Safety
Violation.
b) Following the correction of the Safety Violation(s), CPS Energy shall issue a Notice
of a Safety Violation Assessment Charge, the form of which is in Appendix B, to the
Attaching Entity, as provided in Appendix H for each Safety Violation(s) noted.
c) The Attaching Entity may dispute responsibility for such Safety Violation
Assessment Charge within fifteen (15) calendar days of CPS Energy’s issuance of
notice. CPS Energy and the Attaching Entity shall meet within fifteen (15) days of
CPS Energy receiving the notice of dispute to review all relevant facts and work
towards an agreement on the question of responsibility of the Safety Violation(s).
CPS Energy will provide its determination of responsibility within ten (10) calendar
days of the determination meeting. Should CPS Energy in its reasonable judgement
determine the Attaching Entity was at fault, the Attaching Entity shall be responsible
for the Safety Violation Assessment Charge. However, should CPS Energy in its
reasonable judgement determine the Attaching Entity is not at fault; CPS Energy may
in its discretion waive the Safety Violation Assessment Charge and investigate to
determine the responsible party. Regardless of CPS Energy’s determination as to the
Safety Violation Assessment Charge, the Attaching Entity that owns the Attachment,
Wireless Installation, or Banner Attachment imposing the Safety Violation is
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required to remedy the Safety Violation within five (5) calendar days of CPS
Energy’s issuance of the Notice of Safety Violation form in accordance with Section
II.K.3.a.
Should the Attaching Entity fail to dispute the Safety Violation Assessment Charge
within fifteen (15) calendar days of CPS Energy issuing the Notice of Safety
Violation Assessment Charge as required by this Section II.K.3.c, the Attaching
Entity shall be required to pay the full amount of any Safety Violation Assessment
Charges levied by CPS Energy within forty-five (45) calendar days from receipt of
invoice. Failure to make timely payment shall result in the following enforcement
measure:
(i) CPS Energy will immediately suspend or stop processing Applications submitted
by the non-compliant Attaching Entity for future Permits until full payment is
received by CPS Energy.
3. Failure to Enforce. Failure of CPS Energy to take action to enforce compliance with
any of the terms and conditions of these Standards shall not constitute a waiver or
relinquishment of any term or condition of these Standards, but the same shall be and
remain at all times in full force and effect until terminated, in accordance with these
Standards or the Pole Attachment, Wireless Installation, or Banner Attachment
Agreement, as appropriate.
L. Conflict Resolution
Notwithstanding the provisions of Section III.A.5 and Section III.A.6; conflicts, both
informal and formal, identified between CPS Energy and an Attaching Entity arising from
and/or related to technical interpretations and/or day-to-day administration of these
Standards shall comply with this Section II.L.
1. Informal Conflict Resolution. Informal conflicts identified between an Attaching
Entity and CPS Energy arising from and/or related to technical interpretations and/or
day-to-day administration of these Standards shall comply with this Section II.L.1.
Notice of an informal conflict shall be submitted via electronic mail to the CPS Energy
representatives identified in Section II.L.1.a below. The party initiating the conflict
notice shall (1) provide a specific detailed description of the conflict including any
previous efforts to remedy the conflict, and (2) call for progressive management
involvement in the resolution process. Both CPS Energy and the Attaching Entity shall
use their best efforts to arrange personal meetings and/or telephone conferences as
needed, at mutually convenient times and places at each of the following successive
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management levels, each of which will have a period of allotted time as specified below
in which to attempt to resolve the conflict:
a) Successive Management Levels (for CPS Energy).
(i) First Level: Pole Attachment Representative (CPS Contractor) – 5 business
days.
(ii) Second Level: Manager, CPS Energy Pole Attachment Services – 10 business
days.
(iii) Third Level: Director, CPS Energy Distribution Engineering – 15 business
days.
b) The allotted time for the first-level of resolution process will begin on the next
business day following the submission of the electronic mail of the conflict by the
submitting party. If a resolution is not achieved at any given management level at
the end of their allotted time, then the allotted time for the negotiators at the next
management level will begin on the next business day unless the parties agree
otherwise to extend the allotted time.
c) If a resolution is reached, CPS Energy shall draft a letter agreement which outlines
the basis of the disagreement, the steps taken to reach settlement, and the settlement
provisions. Both CPS Energy and the Attaching Entity shall provide their affirmative
support of the agreed resolution.
d) If a resolution is not achieved at the final management level within their allotted time
at the operation level, then either party is directed to follow the Dispute Resolution
process as defined in the Pole Attachment, Wireless Installation, or Banner
Attachment Agreement, as appropriate, for further escalation.
2. Formal Process. Where these Standards provide CPS Energy with the authority to
determine whether an Attaching Entity or its Attachments, Wireless Installations, or
Banner Attachments are in violation of any Applicable Engineering Standard or of any
provision of these Standards, CPS Energy shall provide the Attaching Entity with written
notice of its investigation into such matters. Such notice shall be provided to the
Attaching Entity’s representative identified in its Attaching Entity Registration & Annual
Reporting Form as required in Section II.B and shall be no fewer than thirty (30) calendar
days prior to the day CPS Energy intends to make a final determination, and shall include
all information in CPS Energy’s possession or control relevant to its investigation and
determination. In cases of Emergency or in other cases in which the notice time periods
set forth in this Section II.L.2 are not feasible, CPS Energy shall endeavor to provide the
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Attaching Entity with as much advance notice of its investigation as possible. The
Attaching Entity may provide additional information to CPS Energy relevant to the
determination within fifteen (15) calendar days of CPS Energy issuing written notice of
its investigation. In the event Attaching Entity provides information that indicates that
CPS Energy incorrectly determined that the Attaching Entity was in violation of any
Applicable Engineering Standard or any provision of these Standards, CPS Energy shall
promptly restore the Attaching Entity to the position it held prior to the determination.
M. Liability Insurance
CPS Energy shall require the liability insurance as described in the Pole Attachment
Agreement for wired Attachments, Wireless Installation Agreement for Wireless
Installations, and Banner Attachment Agreement for Banner Attachments, as appropriate, in
addition to the requirements of Section IV.D.4.
N. Indemnification
CPS Energy shall require the indemnification as described in the Pole Attachment Agreement
for wired Attachments, Wireless Installation Agreement for Wireless Installations, and
Banner Attachment Agreement for Banner Attachments, as appropriate, in addition to those
indemnification provisions provided in these Standards.
O. Performance Bond
CPS Energy shall require Attaching Entity to secure and maintain a performance bond as
described in the Pole Attachment Agreement for wired Attachments, Wireless Installation
Agreement for Wireless Installations, and Banner Attachment Agreement for Banner
Attachments, as appropriate.
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SECTION III.
GENERAL TECHNICAL
PROVISIONS
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III. GENERAL TECHNICAL PROVISIONS
A. General Design & Construction Standards & Specifications
1. Professional Engineer. An Attaching Entity shall utilize a licensed Professional
Engineer to undertake and complete the engineering design and Pole Loading Analysis
(PLA) calculations required in completing an Application for Permit as described in
Section IV and Section V. For the purposes of these Standards, an Engineer shall include
engineering employees or contractors with a valid state of Texas professional engineering
license in good standing. All Engineers considered by the Attaching Entity must be
approved by CPS Energy before undertaking any engineering work on behalf of the
Attaching Entity. CPS Energy approval shall not be unreasonably withheld, conditioned,
or delayed. CPS Energy shall maintain a list of pre-approved Engineers on its website.
The Attaching Entity’s Engineer shall adhere to all Applicable Engineering Standards
and requirements of CPS Energy. Failure to comply with such standards and
requirements may result in CPS Energy retracting its approval of the Engineer. If CPS
Energy reasonably determines that non-compliance by the Engineer resulted in
substandard work, the Attaching Entity shall be required to remedy all work conducted
by the Engineer that does not comply with the Applicable Engineering Standards and any
other requirements of CPS Energy at the sole expense of the Attaching Entity.
2. Contractors. All work, with the exception of One-Touch Simple Transfers and Pole
Top Antenna installations, performed on CPS Energy Facilities on behalf of an Attaching
Entity pursuant to a Permit shall be done by its own employees, contractors, or
subcontractors approved by CPS Energy, which approval shall not be unreasonably
withheld, delayed, or conditioned. One-Touch Simple Transfers and Pole Top Antenna
installations shall only be undertaken by contractors certified and approved by CPS
Energy for such work pursuant to Section IV.B.5.b All employees, contractors, and
subcontractors utilized by the Attaching Entity shall be subject to the same standards of
conduct and behavior as CPS Energy applies to its own contractors and employees, as
set forth in Appendix M and Appendix N, which CPS Energy may reasonably revise
upon thirty (30) calendar days’ notice. Failure of any employee, contractor, or
subcontractor of the Attaching Entity to adhere to and comply with such CPS Energy
standards and requirements may result in CPS Energy retracting its approval of the
employee, contractor, or subcontractor to perform work of any kind on CPS Energy
Facilities.
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The Attaching Entity shall bear full responsibility for ensuring its employees, agents,
contractors, and subcontractors are in full compliance with the requirements of these
Standards. An Attaching Entity may be required to remedy any and all work, conducted
by either its employees, contractor, or subcontractor that does not comply with the
Applicable Engineering Standards and other construction standards and requirements of
CPS Energy. CPS Energy reserves the right to halt all work undertaken by the Attaching
Entity or its contractors/subcontractors that in CPS Energy’s sole discretion is deemed
unsafe or undertaken contrary to CPS Energy standards and requirements.
3. Right to Review. CPS Energy contemplates relying upon the Attaching Entity’s Pre-
Construction Survey and other engineering/field evaluation reports developed and relied
upon in connection with any Application submitted be the Attaching Entity. Nonetheless,
CPS Energy reserves the right to perform its own (either by CPS Energy employees or
contractors) engineering and field evaluation or verification as appropriate or necessary.
The costs for CPS Energy to undertake such additional engineering and field evaluation
shall be paid by the Attaching Entity pursuant to Section IV, Section V, Section VI, and
Section II.I.2.
4. Installation/Maintenance of Communications Facilities. All Attaching Entities shall
be responsible for the installation and maintenance of their Communications Facilities,
Wireless Installations or Banner Attachments in accordance with the requirements and
specifications set out in these Standards, including the Appendices. An Attaching Entity
shall at all times and at its own expense make and maintain its Attachments,
Overlashings, Wireless Installations, and Banner Attachments in a safe and workmanlike
manner, and keep them in good repair and condition in accordance with all Applicable
Engineering Standards.
Notwithstanding the foregoing; Attachments, Overlashings, Wireless Installations, and
Banner Attachments which complied with the Applicable Engineering Standards at the
time they were originally installed may be operated in place until such time that such
facilities are subject to modification, upgrade, rebuild, repair, transfer, relocation, or
other such changes at which time, these facilities will be required to comply with the then
current Applicable Engineering Standards.
a) Protective Equipment. The Attaching Entity, its employees and contractors, shall
install and utilize adequate protective equipment to ensure the safety of people and
facilities. The Attaching Entity shall install, at its own expense, protective devices
designed to handle the voltage and current impressed on its Communications
Facilities or Wireless Installations in the event of a contact or due to close proximity
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with a supply conductor(s) or other energized equipment. CPS Energy shall not be
liable for any actual or consequential damages to the Attaching Entity’s
Communication Facilities, Wireless Installations, or the Attaching Entity’s
customers’ facilities resulting from such contact or proximity with CPS Energy’s
supply conductor(s) or other energized equipment.
5. Conflicts within the Standards. If there exists a difference or conflict in the Applicable
Engineering Standards, the following rules will apply:
a) if one Applicable Engineering Standard is more stringent than the other, the more
stringent shall apply;
b) if one of the conflicting specifications, regulations, or practices is not more stringent
than the other, the specification, regulation, or practice of the National Electrical
Safety Code (NESC) will apply; or
c) if the conflict cannot be resolved under the first two rules, CPS Energy will determine
in good faith which specification, regulation, or practice shall apply, with safety
concerns given the highest priority in such determination, subject to the conflict
resolution procedures outlined in Section II.L.1.
An Attaching Entity shall not be penalized in any manner for non-compliance with
conflicting standards that are resolved pursuant to subpart (c) of this Section III.A.5
provided the Attaching Entity identifies the potential conflict to CPS Energy in writing
at least seven (7) days before actual construction of the Attachment, Overlash, Wireless
Installation, or Banner Attachment began.
6. Request Waiver. An Attaching Entity may request a waiver of specific items of the
Applicable Engineering Standards by submitting a properly completed CPS Energy
Request for Waiver of Applicable Engineering Standards form (Waiver Request), a copy
of which is in Appendix B and available on the CPS Energy Pole Attachment website,
www.cpsenergy.com/poleattachments, either before or at the time of Application
submission. The request must specifically identify the Applicable Engineering Standard
requested to be waived, justification for requesting the granting of the waiver, and the
proposed solution as a result of the waiver. CPS Energy shall notify the Attaching Entity
in writing within seven (7) calendar days of receiving a properly completed Waiver
Request form. CPS Energy will not grant any waiver which in the sole opinion of CPS
Energy will result in a violation of the NESC or other applicable federal, state, or local
law, regulation, or ordinance.
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7. Tagging. Each Attaching Entity shall properly install identification Tags on all of its
Attachments, Overlashings, Wireless Installations, and Banner Attachments as specified
in Appendix K and/or applicable federal, state, local, or industry regulations in effect at
the time of installation. With regard to Banner Attachments, in addition to tagging all
pole-mounted hardware, temporarily displayed Banners shall include an identification
Tag made of fabric and sewn onto the Banner material. Failure of an Attaching Entity to
provide proper tagging of its Attachments, Overlashings, Wireless Installations, or
Banner Attachments, or failure to undertake in good faith its Tagging Plan shall be
considered a violation of the Applicable Engineering Standards.
a) Should CPS Energy discover that an Attaching Entity has Attachments,
Overlashings, Wireless Installations, or Banner Attachments that are untagged or
incorrectly tagged6, excluding Service Drops, exceeding five percent (5%) of its total
Attachments, Wireless Installations or Banner Attachments respectively, the
Attaching Entity, at CPS Energy’s request, shall within two (2) months, provide to
CPS Energy a written plan (Tagging Plan) to Tag the Attachments, Overlashings,
Wireless Installations, or Banner Attachments. The Tagging Plan shall identify an
estimated schedule to complete the tagging of all untagged or incorrectly tagged
Attachments, Overlashings, Wireless Installations, or Banner Attachments within an
eighteen (18) month period for Attachments and Overlashings and within two (2)
months for Wireless Installations and Banner Attachments. The Attaching Entity and
CPS Energy shall meet every two months during the timeframe outlined in the
Tagging Plan to determine Attaching Entity’s compliance with its Tagging Plan. CPS
Energy reserves the right to conduct field audits to assess the Attaching Entity’s
compliance with its Tagging Plan.
b) In the event any Attachment, Overlash, Wireless Installation, or Banner Attachment
is untagged or incorrectly tagged and CPS Energy must determine the owner’s
identity in order to address the repair or maintenance of a CPS Energy Facility where
CPS Energy cannot undertake such repair or maintenance absent the removal or
transfer of such Attachment, Overlash, Wireless Installation, or Banner Attachment;
CPS Energy will undertake the following protocol:
(i) A thirty (30) minute reasonable effort to determine the owner of the untagged
Attachment, Overlash, Wireless Installation or Banner Attachment at no cost to
the Attaching Entity; then
(ii) Provided the initial thirty (30) minute effort is unsuccessful, CPS Energy shall
continue with its search until ownership is determined. CPS Energy shall bill
6 As to the current ownership of the Attachment, Overlash, Wireless Installation, or Banner Attachment.
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and the non-compliant Attaching Entity shall pay CPS Energy at the Tracing
Line Ownership rate set forth at Appendix H for the time required to determine
the Attachment, Overlash, Wireless Installation, or Banner Attachment
ownership.
8. Physical Interference with CPS Energy Facilities. An Attaching Entity shall not allow
its Communications Facilities, Wireless Installations, or Banner Attachments to impede,
impair, or interfere with the installation, placement, or operation of any CPS Energy
Facilities. An Attaching Entity whose Communications Facilities, Wireless Installations,
Banner Attachments, or any part thereof; impede, impair, or interfere with any CPS
Energy Facilities shall correct such condition within fifteen (15) calendar days from
receipt of written notice of such impairment from CPS Energy. Failure to timely correct
such condition will result in CPS Energy, at its option, taking all necessary steps to
correct said condition at Attaching Entity’s expense plus ten-percent (10%). CPS Energy
will attempt to notify the non-compliant Attaching Entity in writing prior to performing
such work whenever practicable.
If an Attaching Entity continues to allow its Communications Facilities, Wireless
Installations, or Banner Attachments to impede, impair, or interfere with the operation of
any CPS Energy Facilities after the initial fifteen (15) calendar day correction period, the
Attaching Entity shall be subject to enforcement action, including but not limited to:
(i) Suspension of the processing any further Applications, by the Attaching Entity,
pending resolution of such interference; and
(ii) Potential contractual claims.
An Attaching Entity shall not be responsible for physical interference with future
installations by other Attaching Entities, provided that the Attaching Entity’s prior
Attachments are duly permitted by CPS Energy and comply with all Applicable
Engineering Standards and the requirements of these Standards at the time of the initial
installation, unless otherwise required by applicable federal, state, or local laws. Where
CPS Energy needs to add to or modify CPS Energy Facilities in a case other than
remedying a non-compliant condition caused by an Attaching Entity, and where that
action would require the replacement of a Pole or Streetlight Pole, as applicable, CPS
Energy and all affected Attaching Entities shall be responsible for their own cost of
transferring their Attachments, Overlashing, Wireless Installations, or Banner
Attachments. CPS Energy will be responsible for the replacement cost of the pole
structure.
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a) No Wireless Installations within Certain Distance from CPS Energy Substations. No
Applications will be approved for a Wireless Installation on CPS Energy Poles or
Overhead Streetlight Poles within two-thousand feet (2000’) of any CPS Energy
Substation’s outer fence.
9. Performance Interference to Attaching Entity’s Customer. To the extent an
Attaching Entity identifies any interference with its Communications Services impacting
its customers that may or may not be related to CPS Energy Facilities, the Attaching
Entity shall not identify CPS Energy to its customers as the source of such interference
absent a test report verifying the source and prior notice to CPS Energy of the report’s
findings. The Attaching Entity shall cooperate with CPS Energy to investigate the source
of any such signal interference and shall at CPS Energy’s request conduct a test, at the
Attaching Entity’s expense, verifying the source of such interference. The test equipment
used for verifying the source of interference must be calibrated to the standards provided
by the National Institute of Standards and Technology or any similar, mutually agreeable
standards organization. In the event such testing provides conclusive evidence that CPS
Energy Facilities are the source of such interference, CPS Energy shall reimburse the
Attaching Entity for the reasonable expense of the testing and will work with Attaching
Entity to find a reasonable mitigation of the interference that does not impose undue
burdens on CPS Energy’s ability to provide electric service.
10. Wireless Interference. All Wireless Installations, including Mid-Span Installations,
shall be operated in such a manner which will not cause Wireless Interference to any
existing or future CPS Energy Facilities, CPS Energy wireless systems or operations, or
governmental public safety facilities or operations. Nor shall they cause Wireless
Interference to the facilities or operations of any other Attaching Entity or FCC-licensed
operator. In the event of Wireless Interference, the Wireless Provider shall shut down
the Wireless Equipment causing such interference within one (1) hour of CPS Energy
contacting the Attaching Entity’s Network Operations Center. If the Attaching Entity
fails to timely shut down the Wireless Equipment, CPS Energy reserves the right to cut
off electricity to the Wireless Installation. Thereafter, following receipt of written notice
of the incident, the Attaching Entity will take all commercially reasonable steps
necessary to permanently eliminate such interference, including but not limited to,
recalibration or replacement of Wireless Equipment, and the subsequent powering down
of such equipment for intermittent testing pursuant to the requirements of Section
III.A.10.c. In the event the Wireless Interference cannot be eliminated through
equipment recalibration or replacement, the Wireless Installation shall be removed and
the Wireless Equipment may be installed at an alternative pole-site that does not cause
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Wireless Interference. These activities shall be carried out by the Wireless Provider at
its own expense.
In the event of Wireless Interference as described in the previous paragraph, the Wireless
Provider shall correct such condition within fifteen (15) calendar days from receipt of
written notice. Failure to timely correct such condition permanently, and the reactivation
of the Wireless Equipment to the same effect, will result in CPS Energy, at its option,
taking all necessary steps to eliminate the reoccurrence of Wireless Interference at
Wireless Provider’s expense. CPS Energy will attempt to notify the non-compliant
Wireless Provider in writing prior to performing such steps whenever feasible. If any
Wireless Provider continues to allow its Wireless Installations to interfere with the
operation of any CPS Energy Facilities as described above after the initial fifteen (15)
calendar day correction period, the Wireless Provider shall be subject to enforcement
action, including but not limited to:
(i) Interruption of CPS Energy supplied power to the identified Wireless
Installation;
(ii) Suspension of the processing any further Applications, submitted by the
Wireless Provider, pending resolution of such interference; or
(iii) Other remedies under the applicable Pole Attachment Agreement and
associated Wireless Addendum, or Wireless Installation Agreement.
In situations where CPS Energy determines that a Wireless Provider’s impairment or
interference condition poses a potential Emergency situation, CPS Energy may perform
such work and/or take such action(s) as it deems necessary to eliminate the potential
Emergency situation without first giving written notice to the Wireless Provider. As soon
as practicable thereafter, CPS Energy will advise the non-conforming Wireless Provider
of the work performed or the action(s) taken. The non-conforming Wireless Provider
shall be responsible for all costs incurred by CPS Energy plus ten-percent (10%) in taking
action pursuant to this Section III.A.10.
a) Interference Studies & Testing. In the Application process, and at Wireless
Interference events, CPS Energy requires the documentation and analysis of testing
for potential and possible Wireless Interference. CPS Energy reserves the right to
hire consultants and industry experts to perform Wireless Interference testing,
investigations, and/or analysis at the sole expense of the Wireless Provider.
(i) Initial Installation - In the Pre-Certification and/or Application process for the
initial installation of the Wireless Installation, an Intermodulation Test report
will be provided by the Wireless Provider.
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(ii) Equipment Upgrades or Replacements - In the Pre-Certification and/or
Application process for an upgrade, or non-like for like replacement of the
initial Wireless Installation, an Intermodulation Test report will be provided by
the Wireless Provider.
(iii) Interference Studies & Testing Report - The Intermodulation Test report will
have an executive summary stating a “highly likely” or “not likely” for potential
intermodulation issues. The intermodulation Test report shall be prepared by
an Engineer trained and certified in radio frequency engineering.
b) At CPS Energy’s sole discretion, a more in-depth radio frequency (RF) interference
study may be required at certain occurrences, to include but not, limited to: 1) “highly
likely” assessment of intermodulation issues in a summary of any Intermodulation
Test report, 2) a known and/or unresolved RF interference complaint. The RF
interference study will require an onsite visit(s) to gather field measurements and site
conditions. The following area will be addressed: intermodulation products –
transmitter and receiver, receiver noise & desensitization, transmitter noise &
harmonics, and spurious emissions. Such RF interference study shall be undertaken
and approved by an engineer, trained and certified in radio frequency engineering.
Additionally, the RF interference report will have an executive summary with action
statement, a method of RF interference remedies (if necessary), and all input
parameters indexed.
c) A Wireless Provider may; intermittently, temporarily, or permanently; shut-off power
to remedy and/or troubleshoot Wireless Interference issues. Electrical service shall
not be reinstated without CPS Energy’s written approval following a request to
reestablish electrical service from the Wireless Provider. CPS Energy reserves the
right to determine if all Wireless Interference issues are remedied prior to granting
approval to reinstate electrical power.
11. Enclosures. Except as to Attaching Entity’s facilities located on Attaching Entity’s
private property and/or easements, no Attaching Entity shall place new pedestals, vaults
and/or other enclosures (excluding Wireless Equipment Cabinets and Slab Mounted
Equipment Cabinets) on or within four (4) feet of any Pole, or other CPS Energy
Facilities without CPS Energy’s prior written permission. The Attaching Entity shall
specifically identify this request in its Application for Permit submittal. If permission is
granted by CPS Energy, all such installations shall be in compliance with the
specifications and drawings provided in Appendix D, Appendix I, or other Applicable
Engineering Standards. An Attaching Entity may retain any pedestals, vaults and/or
other enclosures located within four (4) feet of any Pole, or other CPS Energy Facilities
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that are in place on or before August 1, 2016, or result as part of a future pole
replacements, provided the Attaching Entity complies with any and all directives issued
by CPS Energy regarding such enclosures.
12. Vegetation Management. Attaching Entities shall be responsible for performing, or
causing the performance of, all tree trimming and other vegetation management
necessary for the safe and reliable installation, use, and maintenance of their
Attachments, Overlashings, Wireless Installations, or Banner Attachments and to avoid
stress on Poles and Streetlight Poles, as applicable, caused by contact between tree limbs
and the Attaching Entities’ Attachments, Overlashings, Wireless Installation, or Banner
Attachments components.
Per NESC, all crossing span and adjoining spans on each side of a line crossing, railroad
crossing, limited-access highway crossing, or navigable waterway requiring a crossing
permit shall be kept free from overhanging or decayed trees or limbs that shall fall into
the line, including both supply and communication cables.7
All tree trimming shall be performed in accordance with OSHA8 regulations and/or local
municipal ordnances, set out in Appendix O, as may be amended from time to time.
Attaching Entities shall use qualified tree trimming contractors approved by CPS Energy
who shall adhere to industry and local municipal ordnances, standards, and requirements
for tree trimming and vegetation management. Failure of a tree trimming contractor to
adhere to and comply with such standards and requirements may result in CPS Energy
retracting its approval of the tree trimming contractor to perform further work of any kind
on or around CPS Energy Facilities. An Attaching Entity may be required to remedy any
and all work, conducted by its tree trimming contractor that fails to comply with the tree
trimming standards and requirements set forth in Appendix O. CPS Energy reserves the
right to halt any and all work by any such tree trimming contractor that CPS Energy in
its discretion deems to be unsafe or performs work contrary to the standards and
requirements set forth in Appendix O and the Applicable Engineering Standards.
13. Removal of Attaching Entity’s Facilities.
a) Abandoned Facilities. An Attaching Entity shall report, through the annual
registration process described in Section II.F, and remove at the Attaching Entity’s
expense; all abandoned, non-functional, and obsolete Attachments, Overlashings,
Wireless Installations, and any related Communications Facilities, as well as Banner
7 NESC Rule 218, Vegetation Management, C2-2017. 8 Occupational Safety and Health Administration (OSHA).
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Attachments, on CPS Energy Poles or Streetlight Poles, as applicable, which the
appropriate Attaching Entity:
(i) No longer utilizes for providing Communications Service or
Telecommunications Services, Wireless Service, or Banner Advertisement
service;
(ii) Has abandoned or plans to abandon during the next reporting period; or
(iii) Has replaced with operating capacity of alternative facilities.
Except as otherwise provided, the Attaching Entity shall remove these facilities
coincident with their replacement, and in all cases within one (1) year of meeting any
of the above conditions, unless the Attaching Entity receives written notice from CPS
Energy that removal is necessary to accommodate CPS Energy’s use of the affected
Poles, pursuant to a reservation of Capacity, in which case the Attaching Entity shall
remove such Attachments, Overlashings, Wireless Installations, or Banner
Attachments within ninety (90) calendar days of CPS Energy issuing such written
notice.
b) Removal on Expiration/Termination. Subject to the expiration or other termination
of an Attaching Entity’s Attachment Contract or any individual Permits, unless
renewed; the Attaching Entity shall submit a written plan which describes the
commitment, schedule, and process for the removal of its Attachments, Overlashings,
Wireless Installations, or Banner Attachments from the affected Poles or Streetlight
Poles, as applicable, to CPS Energy for approval. CPS Energy shall review such plan
and either approve or request additional details within fifteen (15) calendar days of
receipt of the plan. Following approval of the plan by CPS Energy, the Attaching
Entity shall make judicious progress toward fulfilling the removal commitments
made by the Attaching Entity in the plan. Such removals will be at the Attaching
Entity’s sole expense. If the Attaching Entity fails to remove such Attachments,
Overlashings, Wireless Installations, Banner Attachments within the timeframe
contemplated by the plan, CPS Energy shall have the right to have such Attachments,
Overlashings, Wireless Installations, or Banner Attachments removed at the
Attaching Entity’s expense without liability to CPS Energy.
14. Pre-Certification of Wireless System. Pursuant to Section V.B.2.d, before submitting
an Application for a Wireless Installation Permit, a Wireless Provider must submit a
completed Request for Pre-Certification of Wireless System form to CPS Energy in order
that the Wireless Equipment configuration proposed for a Wireless Installation be
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approved for installation on a Pole or Overhead Streetlight Pole as part of the Pre-
Certified Equipment process. A copy of this form is located in Appendix B and can be
downloaded at www.cpsenergy.com/poleattachments. CPS Energy requires the initial
configuration of a specific technology of a Wireless Installations for each Wireless
Provider to be pre-certified in order to minimize potential interference with
communication equipment essential to CPS Energy’s core electric operations and for
public safety. The pre-certification process shall consist of three key activities: (i) testing
for Wireless Interference; (ii) mock representation of the proposed Wireless Installation;
and (iii) review and approval of the Request for Pre-Certification of Wireless System
form.
a) Testing for Wireless Interference. The Wireless Provider shall identify in writing all
FCC licensed frequencies, by FCC licensee, that will be used as part of a Wireless
Installation and CPS Energy shall disclose all licensed and unlicensed frequencies
utilized in its operations. The Wireless Provider will then conduct and submit the
reports required by Appendix D, Section B.1.
b) Representation of Wireless Installation. The Wireless Provider shall coordinate with
the Pole Attachment Manager a schedule for the mock installation of a proposed
Wireless Installation at CPS Energy’s training yard, in compliance with Appendix D,
Section B. 13. The Pole Attachment Manager shall schedule a date for the mock-up
installation to begin within thirty (30) days of a written request.
CPS Energy will conduct its timely review of the Request for Pre-Certification of
Wireless System form in conjunction with the evaluation of the Wireless Provider’s
mock-up display of the Wireless Installation and submitted Wireless Interference reports.
CPS Energy shall complete the review of the aforementioned form and report within
thirty (30) days of completion of the mock-up installation, and either approve or reject
the proposed configuration of the Wireless Installation provided all other pre-
certification requirements have been met including compliance with all the requirements
of Appendix D. If the Wireless Provider is aware that it has not met all of the
requirements for pre-certification prior to expiration of the initial thirty (30) day review
period, the Wireless Provider may request an additional thirty (30) days to complete the
requirements.
B. Pole Modifications and /or Replacements
1. Restrictions on Certain Poles. CPS Energy may deny an Application for Permit for
access to a Pole or Overhead Streetlight Pole (as appropriate for the type of installation)
in flood zones, river crossings or other such locations, or if the proposed new Attachment,
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Wireless Installation, or Banner Attachment cannot be accommodated without creating
a potential to disrupt or impair CPS Energy Facilities or endanger the safety of people or
facilities. In such instances, CPS Energy, in its sole discretion or solution, may erect a
taller/larger pole structure to accommodate an Attaching Entity’s Attachment, Wireless
Installation, or Banner Attachment if the costs of such replacement pole or solution is
approved by and paid by the Attaching Entity in advance.
Further, CPS Energy may require the removal or modification of an existing Attachment,
Wireless Installation, or Banner Attachment at the Attaching Entity’s expense, if CPS
Energy reasonably determines that such Attachment, Wireless Installation, or Banner
Attachment did not meet the clearance requirements set forth in the Standards at the time
of installation or modification, or may create a potential to disrupt or impair CPS Energy
Facilities or endanger the general safety of people or facilities.
a) Steel Poles. CPS Energy will consider requests by an Attaching Entity to access
existing distribution steel Poles.
(i) Steel Poles. Attachments must be firmly secured with clamps and/or stainless
steel banding. The drilling of any additional holes into steel Poles or associated
equipment is prohibited. The only exception permitted is the use of a self-
tapping set screw for grounding of equipment on steel Poles. Regarding
Wireless Installations, a Wireless Provider may request access to a steel Pole or
Overhead Streetlight Pole provided the components of the Wireless Installation
are secured with clamps. All Riser cables necessary to connect the components
of the Wireless Installation must be installed outside the steel Pole using a U-
Guard, provided the structural integrity of the Pole is maintained.
b) Distribution Poles with Overhead Street Lights. Subject to these Standards, CPS
Energy will provide access to Overhead Streetlights for the purpose of
accommodating Wireless Installations, provided that such installations do not
interfere with the maintenance and operation of the Overhead Streetlights.
c) Transmission Structures. CPS Energy’s transmission poles, towers, or other
structures are outside of the scope of these Standards and the Pole Attachment,
Wireless Installation Agreement, or Banner Attachment Agreement. No
Attachments, Wireless Installations, or Banner Attachments are permitted on CPS
Energy transmission poles, towers, or other structures regardless of the presence of
distribution under-build facilities.
d) Poles with Distribution Equipment Installed. Wireless Installations are prohibited on
any CPS Energy Pole that has electric distribution equipment installed on them such
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as, but not limited to: transformers, capacitors, reclosers, sectionalizers, voltage-
regulators, voltage-regulator racks, primary metering, etc.
e) Mid-Span Installations. The restrictions applicable to Wireless Installations
outlined above in Sections III.B.1 c and d apply to Mid-Span Installations; however,
section III.B.1 a and b are only applicable to Mid-Span Installations as described
below, provided such installations otherwise comply with all Applicable Engineering
Standards.
(i) Steel Poles. All Riser cables necessary to connect the components of a Mid-
Span Installation back to the Slabe Mounted Equipment Cabinet must be
installed outside the steel Pole using U-Guard, provided the structural
integrity of the Pole is maintained.
(ii) Distribution Poles with Overhead Street Lights. Subject to these Standards,
CPS Energy will provide access to Overhead Streetlight Poles for the purpose
of accommodating Mid-Span Installations, provided that such installations do
not interfere with the maintenance and operation of the overhead street lights.
f) Foreign Poles. Many of the pole structures to which CPS Energy’s electrical lines
are attached are not owned by CPS Energy and are outside the scope of these
Standards. Therefore, CPS Energy cannot give permission to attach to such pole
structures. The Attaching Entity is solely responsible for obtaining permission from
the respective pole owner to install any Attachments, Wireless Installations, or
Banner Attachments on such non-CPS Energy owned pole structures outside the
scope of these Standards.
2. CPS Energy Not Required to Relocate. Except as provided by the Make-Ready
Electrical Construction process outlined in Section IV.B.4, Section IV.D.4, Section
V.B.4, and Section VI.B.4, no provision of these Standards requires CPS Energy to
relocate, modify, or replace any Pole, Streetlight Pole, or other CPS Energy Facility for
the benefit of any Attaching Entity, provided; however, that any denial by CPS Energy
for modification of a pole structure or facility is applied in a nondiscriminatory manner
to all Attaching Entities.
3. Guying. All guying, including the installation of independent anchors for each
Attachment requiring guying to accommodate an Attaching Entity’s Attachments,
Wireless Installations, or Banner Attachments shall be provided by and at the expense of
the Attaching Entity to the satisfaction of CPS Energy as specified in the Applicable
Engineering Standards and in Appendix D.
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4. Aesthetic or Civic Projects. From time-to-time, CPS Energy undertakes aesthetic or
Civic Projects as required by ordinance or directive of the City or other governmental
entities that direct CPS Energy to relocate or underground its facilities which will result
in the removal of Poles or Streetlight Poles by CPS Energy upon completion of the
aesthetic or Civic Project.
a) For any project that CPS Energy undertakes for reasons as set forth in this Section
III.B.4 herein, CPS Energy will provide the affected Attaching Entities the estimated
design and construction schedule applicable to each specific aesthetic or Civic Project
as soon as reasonably practical after CPS Energy receives such design and
construction schedule from the appropriate project authority; but not less than forty-
five (45) calendar days of the date CPS Energy expects to receive formal
authorization or a directive to begin work. In this specific circumstance, CPS Energy
will not require the Attaching Entity to submit an Application for the transfer of its
Attachments, Wireless Installations, or Banner Attachments to a new Pole or
Streetlight Pole, as applicable, in the case of a pole line relocation for the aesthetic of
Civic Project provided the Attaching Entity is actively engaged in the overall utility
coordination of the aesthetic or Civic Project. Based on this joint utility coordination,
CPS Energy will require written notification of the Attaching Entity’s intent to
transfer its Attachments, Wireless Installations, or Banner Attachments to the new
Pole or Streetlight Pole, as applicable. CPS Energy will perform a Post-Construction
Inspection as described in Section II.A.76.
Alternatively, should the Attaching Entity not participate in the utility coordination,
described in this Section III.B.4.a, of the aesthetic or Civic Project; CPS Energy shall
require the Attaching Entity to submit an Application for Permit pursuant to the
procedures detailed in either Section IV.B, Section IV.C, Section IV.D, Section IV.E,
Section V.C, or Section VI.C, as appropriate.
b) In the event CPS Energy is required to relocate its aerial electric distribution facilities
underground, CPS Energy will accommodate any affected Attaching Entity in the
design and construction of underground facilities, contingent upon the Attaching
Entity entering into a Joint Trench Agreement with CPS Energy. All parties
executing such Joint Trench Agreement will have an opportunity to install their
conduits during the timeframe that CPS Energy has allowed for the relevant trenching
to occur. Trenching, boring and other common construction costs for the joint
trenching shall be shared by the parties per the Joint Trench Agreement. If any
affected Attaching Entity declines to do so, CPS Energy shall provide it written notice
forty-five (45) calendar days in advance of the date upon which CPS Energy will
remove the Poles or Streetlight Poles affected by the relevant aesthetic or Civic
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Project. CPS Energy shall bear no responsibility to any Attaching Entity in any
manner for the removal of Attachments, Wireless Installations, or Banner
Attachments from the applicable Poles or Streetlight Poles subject to removal.
c) In the event a Wireless Provider has affixed a Wireless Installation on a Pole or
Overhead Streetlight Pole that is subject to removal as a result of an aesthetic or Civic
Project, the Wireless Provider shall remove the Wireless Installation at its own
expense within the time frame specified in this Section III.B.4. At the Wireless
Provider’s option, CPS Energy may accommodate the removed Wireless Installation
at another available pole at the Attacher’s expense pursuant to a new Application..
CPS Energy makes no guarantee that an alternative pole may be permitted in the
general vicinity of the aesthetic or Civic Project location.
d) If any affected Attaching Entity fails to:
(i) relocate its Attachments, Wireless Installations, or Banner Attachments within
forty-five (45) calendar days of issuance of written notice from CPS Energy or
such other period of time on which the parties agree; or
(ii) find other means to accommodate their Attachments, Wireless Installations, or
Banner Attachments.
CPS Energy shall have the right to remove such Attachments, Wireless Installations, or
Banner Attachments at the Attaching Entity’s expense without liability to CPS Energy..
5. Underground Relocation. This Section III.B.5 applies to any underground relocation
that CPS Energy undertakes that is not either an aesthetic, Civic Project, or customer
requested relocation.
a) If CPS Energy decides to move its aerial electric distribution system underground,
CPS Energy shall notify all affected Attaching Entities as soon as practical. As a
result of this notification, affected Attaching Entities shall:
(i) relocate their Attachments, Wireless Installations, or Banner Attachments
within sixty (60) calendar days of issuance of written notice of the construction
date from CPS Energy or such other period of time on which the parties agree;
or
(ii) find other means to accommodate their Attachments, Wireless Installations, or
Banner Attachments.
b) Under these circumstances, CPS Energy will accommodate the affected Attaching
Entities in the design and construction of underground facilities, contingent upon the
Attaching Entity entering into a Joint Trench Agreement with CPS Energy. All
parties executing such Joint Trench Agreement will have an opportunity to install
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their conduits during the timeframe that CPS Energy has allowed for the relevant
trenching to occur. Trenching, boring and other common construction costs for the
joint trenching shall be shared by the parties per the Joint Trench Agreement.
c) If any affected Attaching Entity fails to:
(i) relocate its Attachments, Wireless Installations, or Banner Attachments within
sixty (60) calendar days of issuance of written notice from CPS Energy or such
other period of time on which the parties agreed; or
(ii) find other means to accommodate their Attachments, Wireless Installations, or
Banner Attachments.
CPS Energy shall have the right to remove such Attachments, Wireless Installations,
or Banner Attachments at the Attaching Entity’s expense without liability to CPS
Energy. Notwithstanding the foregoing, CPS Energy shall negotiate in good faith to
provide conduit occupancy rights to the affected Attaching Entities if CPS Energy
moves its aerial system underground pursuant to the Attaching Entity executing a
Joint Trench Agreement with CPS Energy.
6. Customer Requested Underground Relocations. This Section III.B.6 applies to any
underground relocation that CPS Energy undertakes that is requested by a specific
customer.
a) If CPS Energy is requested to move its aerial electric distribution system underground
by a customer, CPS Energy shall notify all affected Attaching Entities as soon as
practical. As a result of this notification, affected Attaching Entities shall:
(i) relocate their Attachments, Wireless Installations, or Banner Attachments
within thirty (30) calendar days of issuance of written notice of the construction
date from CPS Energy or such other period of time on which the parties,
including the customer, agree; or
(ii) find other means to accommodate their Attachments, Wireless Installations, or
Banner Attachments.
b) Under these circumstances, CPS Energy will accommodate the affected Attaching
Entities in the design and construction of underground facilities, contingent upon the
Attaching Entity entering into a Joint Trench Agreement with CPS Energy. All
parties executing such Joint Trench Agreement will have an opportunity to install
their conduits during the timeframe that CPS Energy has allowed for the relevant
trenching to occur. Trenching, boring and other common construction costs for the
joint trenching shall be shared by the parties per the Joint Trench Agreement.
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c) If any affected Attaching Entity fails to:
(iii) relocate its Attachments, Wireless Installations, or Banner Attachments within
thirty (30) calendar days of issuance of written notice from CPS Energy or such
other period of time on which the parties, including the customer, agreed; or
(iv) find other means to accommodate their Attachments, Wireless Installations, or
Banner Attachments.
CPS Energy shall have the right to remove such Attachments, Wireless Installations,
or Banner Attachments at the Attaching Entity’s expense without liability to CPS
Energy or the customer. Notwithstanding the foregoing, CPS Energy shall negotiate
in good faith to provide conduit occupancy rights to the affected Attaching Entities
if CPS Energy moves its aerial system underground pursuant to the Attaching Entity
executing a Joint Trench Agreement with CPS Energy.
7. Replacement of Pole with Pole Top Antenna. In the event a Pole Top Antenna has
been installed on a Pole that is subject to replacement, the Wireless Provider shall, at its
own expense, relocate the Wireless Installation, including the Pole Top Antenna, to the
new replacement Pole, top the existing Pole, and simultaneously transfer CPS Energy’s
Facilities to the replacement Pole within thirty (30) calendar days. The Wireless Provider
must identify a contact person that will be responsible for coordinating the transfer of the
Wireless Installation and the CPS Energy Facilities, and must respond to CPS Energy’s
request to relocate within five (5) calendar days of initial notification. This process shall
apply to a One-Touch Transfer.
8. Abandonment or Removal of CPS Energy Facilities.
a) Notwithstanding the provisions of Section III.B.4, Section III.B.5, or Section III.B.6,
if CPS Energy decides at any time to abandon, remove or underground any Pole or
Streetlight Poles on which one or more Attaching Entities have Attachments,
Overlashings, Wireless Installations, or Banner Attachments; CPS Energy shall give
the affected Attaching Entities notice in writing to that effect as soon as practical, but
at least forty-five (45) calendar days prior to the date on which CPS Energy intends
to abandon or remove such Pole or Streetlight Poles. Notice may be limited to thirty
(30) calendar days if CPS Energy is required to remove or abandon its Facilities as
the result of the action of a third-party and the greater notice period is not practical.
Such notice shall indicate whether CPS Energy is offering the Pole or Streetlight
Poles for sale.
b) If, following the expiration of the applicable notice period, the affected Attaching
Entities have not yet removed and/or transferred all their Attachments, Overlashings,
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Wireless Installations, or Banner Attachments therefrom and no single Attaching
Entity entered into an agreement to purchase the abandoned Pole or Streetlight Poles
pursuant to Section III.B.7.c below; CPS Energy shall have the right to have the
Attachments, Overlashings, Wireless Installations, or Banner Attachments of the
affected Attaching Entities removed and/or transferred from the Pole or Streetlight
Poles at the respective Attaching Entity’s expense plus ten-percent (10%). CPS
Energy shall give the Attaching Entity ten (10) calendar days prior written notice of
any such removal or transfer of Attaching Entity’s Attachments, Overlashings,
Wireless Installations, or Banner Attachments unless circumstances dictate a shorter
time period.
c) Should CPS Energy decide to abandon a Pole or Streetlight Pole; CPS Energy, in its
sole and non-discriminatory discretion, may grant an interested Attaching Entity the
option of purchasing such Pole or Streetlight Pole at a rate negotiated with CPS
Energy. The interested Attaching Entity must notify CPS Energy in writing within
twenty-one (21) calendar days of the date of CPS Energy’s notice of abandonment
that the Attaching Entity desires to purchase the abandoned Pole or Streetlight Pole.
Thereafter, within forty-five (45) calendar days, the Attaching Entity must also secure
and deliver proof of all necessary governmental approvals and easements allowing
the Attaching Entity to independently own and access the pole within the forty-five
(45) calendar day period. Should the Attaching Entity fail to secure the necessary
governmental approvals, or should CPS Energy and the Attaching Entity fail to enter
into an agreement prior to the end of the forty-five (45) calendar day period, the
Attaching Entity must remove its Attachments, Overlashings, Wireless Installations,
or Banner Attachments as required under Section III.B.7.a. CPS Energy is under no
obligation to sell any Attaching Entity any Pole or Streetlight Pole that it intends to
remove or abandon.
9. Allocation of Costs.
a) The cost allocation under this Section III.B.9 only applies when CPS Energy intends
to modify or replace a Pole or Streetlight Pole solely for its own electric business
requirements, including pole maintenance requirements, and not for an aesthetic,
Civic Project, or customer requested purposes under Section III.B.4 or Section III.B.6
respectively. The costs for any rearrangement or transfer of an Attaching Entity’s
Attachment, Wireless Installation, Banner Attachment, or the replacement of a Pole
or Streetlight Pole; including any related costs for tree-cutting or trimming required
to clear the new location of CPS Energy’s cables or wires, shall be allocated to CPS
Energy which shall also be responsible for costs related to the modification or
replacement of the implicated pole structure. Any affected Attaching Entity shall be
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responsible for the rearrangement or transfer of its Attachment, Wireless Installation,
or Banner Attachment at its expense.
b) Prior to making any such pole modification or replacement, CPS Energy shall provide
the affected Attaching Entity written notice of at least forty-five (45) calendar days
of its intent to allow the Attaching Entity a reasonable opportunity to elect to modify
or transfer the existing Attachment, Wireless Installation, or Banner Attachment.
Should the Attaching Entity so elect, it must seek CPS Energy’s written permission.
The notification requirement of this Section III.B.8.b shall not apply to Emergency
situations.
C. Overlashing
1. Application Required. Refer to Section IV.B for details on the Application process for
new Attachments and Overlashings and Section IV.F for the Application process for
Overlashing existing Attachments. Regardless of Overlashing size or methodology,
Attaching Entities are required to maintain their Overlashing in compliance with the
Applicable Engineering Standards in effect at the time of the Overlash installation except
where a change is required by applicable law.
2. Overlashing Third-Party Facilities. An Attaching Entity is prohibited from
Overlashing Communications Facilities of a third-party, including an Affiliate of the
Attaching Entity, unless both the Attaching Entity and third-party have registered and
executed a Pole Attachment Agreement with CPS Energy pursuant to Section II.B and
Section II.C respectively. CPS Energy shall not grant a Permit authorizing the
Overlashing of a third-party’s Communications Facilities unless the Attaching Entity that
owns the Attachments subject to Overlash has provided CPS Energy its consent in
writing to such Overlashing.
3. Annual Attachment Connection Fee. An Attaching Entity or an Overlashing third-
party shall not be required to pay a separate annual Attachment Connection Fee for such
Overlashed Communications Facilities provided that the an annual Attachment
Connection Fee is already being billed for the original Attachment that was Overlashed.
D. Inspection and Inventory of Attaching Entity’s Facilities
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1. Inspections. CPS Energy, at its discretion and in addition to any inspections undertaken
during Make-Ready Work and Post-Construction Inspections, may engage in two other
specific types of inspections or Inventory of Attachments, Wireless Installations, and
Banner Attachments. These include: 1) routine visual inspections of Attachments,
Wireless Installations, and Banner Attachments that CPS Energy employees may conduct
at any time (Section III.D.2); and 2) a formal Inventory that CPS Energy may conduct no
more frequently than once every five (5) years9, in which CPS Energy shall undertake
with its own personnel or with outside contractors, subject to a formal competitive
bidding basis, the cost of which shall be borne by all Attaching Entities on a pro-rata
basis (Section III.D.3). Regardless of inspection or Inventory method:
a) CPS Energy expects an Attaching Entity to install, maintain, and inspect its
Attachments, Overlashings, Wireless Installations, or Banner Attachments to ensure
these facilities are in good order and safe to the general public at all times. If any
inspection reveals that any Attaching Entity’s Attachments, Overlashings, Wireless
Installations, or Banner Attachments are not in compliance with the Applicable
Engineering Standards in effect at the time the Application was approved, CPS
Energy shall provide written notice and the Attaching Entity shall make any and all
corrections to bring the Attachment, Overlash, Wireless Installation, or Banner
Attachment into compliance with the Applicable Engineering Standards. If the
severity of the non-compliance warrants, CPS Energy will assess and the Attaching
Entity will be required to pay a Safety Violation Assessment as described in
Appendix H.
b) If it is found that an Attaching Entity has made an Attachment, Wireless Installation,
or Banner Attachment without a Permit, the Attaching Entity shall pay an
Unauthorized Attachment Charge, Unauthorized Wireless Installation Charge, or
Unauthorized Banner Attachment Charge as specified in Appendix H, in addition to
applicable Attachment Connection Fees, Application Fees, and Make-Ready
Charges, if any.
c) Notwithstanding any other provisions contained in these Standards, including this
Section III.D, no revisions to the Applicable Engineering Standards shall be
retroactive to existing permitted Attachments, Overlashings, Wireless Installations,
or Banner Attachments unless required by city, county, state, or federal law.
d) Subject to Section III.D.1.c), all Attachments, Overlashings, Wireless Installations,
and Banner Attachments must comply with the Applicable Engineering Standards in
9 CPS Energy to complete such an Inventory in 2018.
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effect at the time of installation or modification of the Attachment, Overlash,
Wireless Installation, or Banner Attachment.
2. Routine Visual Inspections and/or Inventory. Any qualified CPS Energy employee
may conduct a routine inspection and/or inventory of an Attaching Entity’s Attachments,
Overlashings, Wireless Installations, or Banner Attachments. In practice, these routine
inspections and/or inventory may be undertaken and completed as part of the daily work
assignment of a CPS Energy employee. The cost of this work is included in the
determination of the annual Attachment Rate or Wireless Rate, as described in Appendix
H. In the course of a routine visual inspection, a CPS Energy employee or contractor
may require an Attaching Entity or its contractors installing an Attachment, Overlash,
Wireless Installation, or Banner Attachment to supply evidence of a valid Permit or
permission from CPS Energy to access a CPS Energy Pole or Streetlight Pole, as
applicable. CPS Energy reserves the right to demand the Attaching Entity or its
contractor to immediately suspend work on the Attachment, Overlash, Wireless
Installation, or Banner Attachment should the Attaching Entity or contractor be unable
to furnish the valid Permit or other notice of permission for CPS Energy’s inspection. If
CPS Energy directs the work be suspended, the Attaching Entity or its contractor shall
suspended the work in a safe and orderly manner ensuring the suspension of the work
will not cause a danger to CPS Energy employees, contractors, or the general public.
3. Formal Inventory Performed by CPS Energy or Third-Party Contractor Subject
To Competitive Bid. CPS Energy may contract with a third-party contractor to conduct
a formal Inventory of either all or designated Poles and Streetlight Poles within the CPS
Energy service area. The cost of this formal Inventory shall not be included in the
calculation of the Attachment Rate, Wireless Rate, or Banner Rate as described in
Appendix H. All Attaching Entities shall cooperate and participate in the Inventory.
Each Attaching Entity will share the total cost of the Inventory on a pro-rata basis with
all other Attaching Entities based on the number of found Attachments, Wireless
Installations, and Banner Attachments belonging to each Attaching Entity. For the
limited purpose of determining the pro-rata shared costs, CPS Energy Facilities will
count as one (1) Attachment on each Pole. In undertaking this formal Inventory:
a) CPS Energy shall have sole responsibility for the management, review, and approval
of the Inventory of its Poles and Streetlight Poles.
b) CPS Energy shall routinely conduct meetings, communicate in writing, via electronic
mail, with all Attaching Entities to discuss the progress and on-going results of the
Inventory. CPS Energy will seek to find consensus with the Attaching Entities as to
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the most effective schedule and methodology of these meetings and communications.
Each Attaching Entity shall be expected to cooperate fully with CPS Energy and/or
the third-party contractor conducting the Inventory by assigning a single point of
contact to attend project meetings and receive the written communications and to
answer any questions either CPS Energy or the third-party contractor may have
concerning the Attaching Entity’s Attachments, Wireless Installations, or Banner
Attachments. Attaching Entities shall be given access to the Inventory results and
other supporting documentation, including maps, spreadsheets, and other related
items. CPS Energy shall post on its webpage information regarding the status of the
Inventory.
c) At the conclusion of the Inventory, CPS Energy shall provide a written report to each
Attaching Entity containing a draft of the final Inventory Attachment, Wireless
Installation, or Banner Attachment count for the Attaching Entity and other
documentation necessary to substantiate the third-party contractor’s Inventory
findings. Notwithstanding the challenge provisions of Section III.D.3.d below, if the
Attaching Entity does not provide a written challenge to the draft Inventory count or
results within thirty (30) calendar days of the issuance of CPS Energy’s draft
Inventory count, the Inventory count will be deemed correct.
d) Should an Attaching Entity wish to challenge the results of the draft Inventory report,
the Attaching Entity shall, within thirty (30) calendar day of CPS Energy issuing the
draft Inventory report, discussed in Section III.D.3.c above, provide CPS Energy
written notice that the Attaching Entity has cause to challenge the results. In this
notice, the Attaching Entity shall provide to CPS Energy all relevant documentation
to substantiate its challenge for review and consideration by CPS Energy. All costs
related to this challenge, including both CPS Energy’s and third-party contractor’s
labor and other expenses required to respond to and resolve the challenge shall be
borne by the Attaching Entity challenging the Inventory results. Should multiple
Attaching Entities provide notice of their intent to challenge the results, CPS Energy
will pro-rate the cost and expenses required to respond to the challenge as described
in this Section III.D.3.d to the Attaching Entities participating in the challenge. To
the extent the Attaching Entity prevails in identifying errors or omissions in the
Inventory, CPS Energy shall be responsible for its own and the third-party contractor
costs. CPS Energy will meet with the Attaching Entity requesting the challenge
within ten (10 calendar days of receiving the written notice of challenge to discuss
the challenge and attempt to reach agreement and settlement on the Attaching Entity’s
Attachment, Wireless Installation, or Banner Attachment count. CPS Energy will
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issue its final decision in writing as to the resolution of the challenge within fifteen
(15) days following this settlement meeting.
e) Following resolution of all challenges, pursuant to Section III.D.3.d, CPS Energy
shall issue a final Inventory report and shall true-up each Attaching Entity’s count to
the number of Attachments, Wireless Installations, or Banner Attachments identified
in the final Inventory report including any Unauthorized Attachments, Unauthorized
Wireless Installations, or Unauthorized Banner Attachments as described in Section
III.E. Unauthorized Attachments, Unauthorized Wireless Installations, or
Unauthorized Banner Attachments reported shall incur an Unauthorized Attachment
Charge, Unauthorized Wireless Installation Charge or Unauthorized Banner
Attachments Charge, as provided in Appendix H. CPS Energy shall invoice the
applicable Attaching Entity for the Unauthorized Attachments, Unauthorized
Wireless Installations, or Unauthorized Banner Attachments and payment shall be
due within forty-five (45) calendar days of CPS Energy’s issuance of the invoice.
Failure of the Attaching Entity to pay the outstanding invoice timely and in full will
result in the suspension of any current pending Applications and the immediate
rejection of any future Applications until such payment is received in full.
4. No Liability. The making of any inspections or Inventory under this Section III.E, or
the failure to do so, shall not operate to impose upon CPS Energy any liability of any
kind whatsoever or relieve an Attaching Entity of any responsibility, obligations or
liability, whether assumed or otherwise existing.
5. Attaching Entity Conducted Inventory. Nothing in these Standards prevents an
Attaching Entity from performing its own Inventory of its own Attachments, Wireless
Installations, or Banner Attachments which CPS Energy shall consider in the
determination of that Attaching Entities total Attachment, Wireless Installation, or
Banner Attachment count. Before CPS Energy will consider such inventory, the
Attaching Entity shall be required to meet with CPS Energy and describe the
methodology and approach used to conduct the inventory. The cost of such inventory
shall be the sole risk and responsibility of the Attaching Entity undertaking the inventory.
E. Unauthorized Occupancy or Access
1. Unauthorized Attachments. If, after the establishment of the Inventory baseline set
forth in Section III.D.3 any Attachments, Wireless Installations, or Banner Attachments
belonging to an Attaching Entity that (1) are found to occupy a Pole or Streetlight Pole,
as applicable, for which CPS Energy had not previously issued a Permit to the Attaching
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Entity, or (2) are being utilized to provide services that are not Communications Services,
Wireless Services, or Banner Advertisement services; CPS Energy, without prejudice to
its other rights or remedies, will send the Attaching Entity a written Notice of the
Unauthorized Attachment, Unauthorized Wireless Installation, or Unauthorized Banner
Attachment , a copy of which is provided in Appendix B. Such notice shall include the
specific location of the Pole or Streetlight Pole where the violation is found and the nature
of the Unauthorized Attachment, Unauthorized Wireless Installation, or Unauthorized
Banner Attachment. Within forty-five (45) calendar days upon receipt of the notice of
violation, the Attaching Entity must submit for the Unauthorized Attachment,
Unauthorized Wireless Installation, or Unauthorized Banner Attachment (1) an
Application for a Permit, (2) the correct Application Fee if applicable, and (3) the
Unauthorized Attachment Charge, Unauthorized Wireless Installations Charge, or
Unauthorized Banner Attachment Charge to CPS Energy. Should the Attaching Entity
fail to comply within the forty-five (45) calendar days, the Attaching Entity must remove
its Unauthorized Attachment, Unauthorized Wireless Installation, or Unauthorized
Banner Attachment within the subsequent forty-five (45) calendar day period. If the
Attaching Entity fails to remove the unauthorized facilities, CPS Energy may remove
them without liability and the Attaching Entity shall promptly reimburse CPS Energy for
the expense plus ten percent (10%) of such removal in all cases, no later than forty-five
(45) calendar days following CPS Energy’s issuance of invoice.
2. Unauthorized Attachment, Unauthorized Wireless Installation Charge, and
Unauthorized Banner Attachment Charge. Pursuant to Section III.E.1 above, CPS
Energy, without prejudice to its other rights or remedies, may assess an Unauthorized
Attachment Charge, Unauthorized Wireless Installation Charge, and Unauthorized
Banner Attachment Charge as specified in Appendix H, for each Attachment, Wireless
Installation, or Banner Attachment for which:
a) No Permit has been issued by CPS Energy;
b) Where an Attachment, Wireless Installation, or Banner Attachment received a Permit
and it was later found the information provided by the Attaching Entity on the
Application was substantially incorrect; or
c) Where an Attachment, Wireless Installation, or Banner Attachment has been
significantly modified since the issuance of its initial Permit and such modification
has not been approved by CPS Energy.
The Unauthorized Attachment Charge, Unauthorized Wireless Installation Charge, and
Unauthorized Banner Attachment Charge shall be due and payable irrespective of
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whether a Permit is subsequently issued to the Attaching Entity for the Unauthorized
Attachment, Unauthorized Wireless Installation, or Unauthorized Banner Attachment.
4. No Ratification of Unauthorized Use. No act or failure to act by CPS Energy with
regard to an Attaching Entity’s Unauthorized Attachments, Unauthorized Wireless
Installations, or Unauthorized Banner Attachments shall be deemed as ratification of the
unauthorized (unlicensed) use. If any Permit should be subsequently issued for an
unauthorized facility, such Permit shall not operate retroactively or constitute a waiver
by CPS Energy of any of its rights or privileges and the non-compliant Attaching Entity
shall remain subject to all liabilities, obligations, and responsibilities under the applicable
Pole Attachment Agreement, Wireless Installation Agreement, Banner Attachment
Agreement and these Standards in regards to said unauthorized (unlicensed) use from its
inception.
5. Excessive Unauthorized Attachments.
a) If an Attaching Entity is determined by CPS Energy pursuant to an Inventory
described in Section III.D or by other means to have Unauthorized Attachments
accounting for the greater of (1) more than two percent (2%) of its total Attachments,
or (2) thirty (30) or more Unauthorized Attachments; the Attaching Entity shall be in
breach of its Pole Attachment Agreement and CPS Energy will have the right to
terminate such Agreement subject to the cure provisions in the Pole Attachment
Agreement. Failure to timely cure such breach of contract could result in the removal
of all of the Attaching Entity’s Communication Facilities, or CPS Energy, in its sole
discretion, may exercise such other remedies as the Pole Attachment Agreement
provides.
b) If an Attaching Entity is determined by CPS Energy pursuant to an Inventory
described in Section III.D or by other means to have any Unauthorized Wireless
Installations or Unauthorized Banner Attachments; the Attaching Entity shall be in
breach of its Wireless Installation Agreement, or Banner Attachment Agreement and
CPS Energy will have the right to terminate such Agreement subject to the cure
provisions in the Wireless Installation Agreement or Banner Attachment Agreement.
Failure to timely cure such breach of contract could result in the removal of all of the
Attaching Entity’s Wireless Installations or Banner Attachments, or CPS Energy, in
its sole discretion, may exercise such other remedies as the Wireless Installation
Agreement or Banner Attachment Agreement provides.
c) For those entities found with Unauthorized Attachments, Unauthorized Wireless
Installations, or Unauthorized Banner Attachments who do not have a valid Pole
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Attachment, Wireless Installation Agreement, or Banner Attachment Agreement, or
who are otherwise not authorized to attach to CPS Energy Poles or Streetlight Poles,
as applicable; CPS Energy reserves all of its rights under applicable law and equity
to remedy the trespass.
F. Operational Duties & Responsibilities
1. Duty to Inspect. While recognizing its duty to maintain and update its electric
distribution system in order to provide safe and reliable electric service, CPS Energy does
not warrant that its Poles are free of defects or non-compliant Attachments, Wireless
Installations, or Banner Attachments. Nor does CPS Energy warrant that its Streetlight
Poles are free of any defects or non-compliant Banner Attachments or Wireless
Installations. By submitting an Application, an Attaching Entity acknowledges that it
has an obligation to inspect CPS Energy’s Poles or Streetlight Poles, as applicable, and
the premises surrounding such pole structures prior to commencing any work utilizing
the Poles or Streetlight Poles or entering the premises surrounding such pole structures.
ANY CPS ENERGY FACILITIES WHICH MAY BE IDENTIFIED AS UNSAFE
SHALL BE REPORTED TO CPS ENERGY AT (210) 353-HELP (353-4357) AS
SOON AS PRACTICAL AFTER THEY ARE IDENTIFIED, FOR FURTHER
HANDLING BEFORE THE ATTACHING ENTITY UNDERTAKES ANY
WORK AT THAT LOCATION.
2. Knowledge of Work Conditions. In all situations, it is the continuing responsibility of
an Attaching Entity to acquaint itself, its employees, agents, contractors, and/or
subcontractors with these Standards including all Applicable Engineering Standards
relating to the work for which a Permit may be sought by the Attaching Entity. Failure
to become familiar with these Standards and with the facilities, difficulties, and/or
restrictions attending the execution of such work may result in the denial of a Permit,
delay in construction, assessment of penalties, and removal of a non-conforming
Attachment, Overlashing, Wireless Installation, or Banner Attachment among other
remedies that CPS Energy may impose for violations of these Standards.
a) CPS Energy Poles and Streetlight Poles may be treated with chemical wood
preservatives.
b) CPS Energy attempts to identify and mark such pole structures that should not be
climbed. In all situations, it the responsibility of any person having a valid reason to
climb a pole structure in performance of assigned job duties to be personally satisfied
as to the structural integrity of such poles prior to climbing or doing other work on
the pole.
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3. Duty of Competent Supervision and Performance. All Attaching Entities are on
notice that in the performance of work under these Standards, an Attaching Entity and its
employees, agents, servants, contractors and/or subcontractors will work near
electrically energized lines, transformers, or other CPS Energy Facilities, and it is
the intention that energy therein will not be interrupted at any time, except in an
Emergency endangering life, personal injury, or property. All Attaching Entities shall
ensure that their employees, agents, servants, contractors and/or subcontractors have the
necessary qualifications, skill, knowledge, training, and experience to protect
themselves, their fellow employees, employees of CPS Energy, and the general public
from harm or injury while performing work permitted pursuant to these Standards. In
addition, all Attaching Entities shall furnish their employees, agents, servants,
contractors and/or subcontractors competent supervision; as well as ensure these
employees, agents, servants, contractors and/or subcontractors have sufficient and
adequate tools, equipment, and training for the required work to be performed in a safe
manner.
In the event of an Emergency or otherwise in which it may be necessary for CPS Energy
to de-energize any part of CPS Energy Facilities, the Attaching Entity shall ensure that
work is suspended until such CPS Energy Facilities have been de-energized and properly
grounded and that no such work is conducted unless and until an authorized CPS Energy
employee has communicated that such CPS Energy Facilities have been made safe and
are ready for the Attaching Entity to work.
4. Requests to De-energize. An Attaching Entity may request that CPS Energy de-
energize and render safe any CPS Energy Facility for its benefit and convenience. Such
request shall be made in writing and received by CPS Energy at least five (5) calendar
days in advance of the date the work is planned. The Attaching Entity shall reimburse
CPS Energy in full for all costs and expenses incurred, in accordance with Section II.I,
to comply with such request. Before any CPS Energy Facilities are de-energized with
the exception of actions taken pursuant to an Emergency; CPS Energy shall provide upon
request an estimate of all costs and expenses to be incurred in accommodating the
Attaching Entity’s request.
5. Interruption of Service. In the event that an Attaching Entity causes an interruption of
service by damaging or interfering with any CPS Energy Facilities, the Attaching Entity
at its expense shall immediately do all things reasonable to avoid further injury or
damages, direct and incidental, resulting therefrom and shall notify CPS Energy
immediately of these activities.
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6. Duty to Inform. THE WORK CONTEMPLATED UNDER THESE STANDARDS
INVOLVES IMMINENT DANGERS INCLUDING SERIOUS BODILY INJURY
OR DEATH FROM ELECTROCUTION. The Attaching Entity acknowledges such
dangers and accepts as its duty and sole responsibility to notify, inform, and keep
informed its employees, agents, servants, contractors and/or subcontractors of such
dangers and shall not be passed or assigned this duty and responsibility to any third-party.
7. Duty to Protect Data. An Attaching Entity has an obligation and duty under Section
§418.181 Texas Government Code (Confidentiality of Certain Information Relating to
Critical Infrastructure) to protect and hold confidential CPS Energy data relating to CPS
Energy Facilities and not disclose such data to any third-party without CPS Energy’s
written consent. CPS Energy will undertake reasonable measures to keep an Attaching
Entity’s proprietary data confidential and secure.
8. Duty to Provide a Safety Briefing. An Attaching Entity that desires to install a Wireless
Installation on the CPS Energy system is required to prepare a Safety Briefing suitable
for CPS Energy employees and contractors who may be required to work near and/or
around such Wireless Installations. The content of the Safety Briefing is to be pre-
approved by CPS Energy before distribution and conveyance to CPS Energy employee
and contractors.
9. Maintenance on CPS Energy Pole Structures. CPS Energy shall de-energize Wireless
Equipment mounted on a Pole or Overhead Streetlight Pole any time its personnel or
contractors are doing maintenance work on such pole structures. CPS Energy shall
provide at least twenty-four (24) hours advance notice of planned maintenance work to
the Wireless Provider’s Network Operations Center by voice message or email. Advance
notice of de-energize of equipment shall not apply in Emergency situations.
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SECTION IV.
SPECIFICATIONS FOR WIRE
ATTACHMENTS
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IV. SPECIFICATIONS FOR WIRE ATTACHMENTS
A. Pole Attachment Application Process
CPS Energy offers Attaching Entities five Application processes for non-discriminatory
access to CPS Poles for wire Attachments or Overlashings as shown in the Figure A and
listed below. Application forms and additional information regarding the CPS Energy Pole
Attachment Program can be downloaded at www.cpsenergy.com/poleattachments.
Competitive Provider - Standard Process.
Described in detail in Section IV.B
Private Network Process.
Described in detail in Section IV.C
Competitive Provider – Area Wide Network Deployment Process.
Described in detail in Section IV.D
Competitive Provider – Network Upgrade Process.
Described in detail in Section IV.E
Competitive Provider – Standard Process for Overlashing Existing Attachments.
Described in detail in Section IV.F.
Attaching Entities who are contemplating or engaged in either a new Area Wide Network
Deployment or undertaking a Network Upgrade are required to contact CPS Energy to
discuss coordination of the Development Plan under the Application process to be used for
the project.
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Figure A: Key Phases and Responsible Parties of the
CPS Energy Pole Attachment Processes
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B. Competitive Provider - Standard Process
A high-level workflow of the Competitive Provider - Standard Process (Standard Process)
for wire Attachments to CPS Energy Poles is illustrated in the Figure B below.
1. Eligibility. Default process for any Attaching Entity with a valid Pole Attachment
Agreement that is a Competitive Provider.
2. Application for Permit Required. An Attaching Entity shall not install any new
Attachment or new Overlashing, except as provided in Section IV.F, on any CPS Energy
Pole without first submitting an Application and obtaining a Permit pursuant to the
requirement and procedures set forth below and elsewhere in these Standards.
a) Application Form. All Attaching Entities shall use the Application for Pole Attachment
Form, a copy of which is provided in Appendix B and available for download at
www.cpsenergy.com/poleattachments, which may be amended from time to time,
provided that any such amendments are consistent with Applicable Engineering
Standards and are applied to all similar types of Attachments on a non-discriminatory
basis.
(i) A single Application may include up to a maximum of one-hundred twenty
(120) Poles for new Attachments.
(ii) CPS Energy’s acceptance of the submitted design documents required as part of
a complete Application Form (Section IV.B.2.e) does not relieve the Attaching
Entity of full responsibility for any errors and/or omissions in the engineering
analysis and compliance with all Applicable Engineering Standards.
b) Service Drops. The submission of an Application is not required to install a Service
Drop on a Pole on which the Attaching Entity already has an authorized Attachment,
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provided that the Attaching Entity provides notice of such Service Drop pursuant to
Section II.F.1 and the Service Drop is installed within the previously authorized
space. Service Drops on Poles for which the Attaching Entity does not have an
authorized Attachment may be authorized by CPS Energy on a monthly basis,
provided the Attaching Entity submits a corresponding Application for Permit within
thirty (30) calendar days of the Service Drop installation.
c) Pole Ownership. For the purposes of Application submittal, unless CPS Energy
records and/or Poles indicate otherwise, CPS Energy shall be presumed to be the
owner all Poles subject to Attachment. The Attaching Entity is responsible for field
verifying Pole ownership and notifying CPS Energy of any discrepancies between
CPS Energy’s maps/records and the actual Poles in the field.
d) Compliance with Standards. Attaching Entity shall comply with the Texas
Engineering Act at Section 1001.001, et seq., of the Texas Occupations Code to the
extent it is applicable to the work described herein, and with the most current version
of the National Electrical Safety Code (NESC), including any and all revisions to
both, and all other Applicable Engineering Standards. The Attaching Entity shall
certify its compliance with the above on each Application it submits to CPS Energy
for processing. The certification statement shall be signed by an employee or agent
of the Attaching Entity who has the final authority or responsibility to approve the
Application. CPS Energy will not process an Application that fails to provide the
signed certification statement included therein. The Attaching Entity shall provide
documentation, sealed by an Engineer, establishing that the Attaching Entity’s
applicable Make Ready Electrical Construction design and Pole Loading Analysis
(PLA) documents comply with all requirements specified by the NESC and the
Applicable Engineering Standards.
(i) Pole Loading Analysis (PLA). An Attaching Entity, in connection with an
Application, must comply with the PLA methodology described herein and in
Appendix G. Acceptable software for use of PLA shall be a commercially
available product with general industry acceptance. Should the Attaching
Entity utilize a commercially available software application that CPS Energy
does not possess; the Attaching Entity shall make available to CPS Energy at
least one software license for CPS Energy use at the Attaching Entity’s expense,
subject to CPS Energy’s Information Technology requirements. The Attaching
Entity will gather the pole and Attachment physical and technical information
required to conduct a PLA on Poles that meet the criteria for PLA as described
in Appendix G, with assistance as required from CPS Energy.
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e) Submission of Application. Completed Applications may be submitted by either U.S.
mail, electronically to [email protected], or other means mutually
agreeable by CPS Energy and the Attaching Entity. The Application shall include:
(i) A completed Application form, as provided in Appendix B;
(ii) Detailed design documents of the required Make-Ready Electrical
Construction, prepared or reviewed by an Engineer which includes the
Attaching Entity’s estimated cost of proposed Make-Ready Electrical
Construction;
(iii) A proposed installation schedule;
(iv) PLA worksheets and results, as required by Appendix G;
(iv) Relevant pole data; and
(v) If applicable, a Waiver Request form, as described in Section III.A.6.
Such Application shall be prepared by, or under the authority of, the Attaching Entity.
The detailed design documents referenced in this Section IV.B.2.e will be undertaken
and completed in design tools to be determined by CPS Energy. All actions pursuant
to this Section IV.B.2.e shall be at the Attaching Entity’s cost and risk.
CPS Energy shall invoice the Attaching Entity the appropriate Application Fee10
pursuant to Section II.I.2 and Appendix H.
3. CPS Energy Review of Application. CPS Energy will respond to each completed
Application and Make-Ready Engineering design documents submitted by the Attaching
Entity within twenty-one (21) calendar days of receipt. Should CPS Energy be required
to return an Application for clarification or modification, the time required for the
Attaching Entity to address the concerns raised and return the Application shall not count
against the twenty-one (21) calendar day period. For Applications with Overlashing
only, CPS Energy will respond pursuant to Section IV.F. Any Application that does not
conform to the requirements provided in Section IV.B.2.e and the Applicable
Engineering Standards will be deemed incomplete and immediately rejected by CPS
Energy. If an Application is rejected as incomplete, the Attaching Entity will be provided
with a detailed description of changes, modifications, or revisions to the Application
necessary for CPS Energy’s review and approval within ten (10) calendar days of receipt
of the Application.
In the event CPS Energy does not finalize its review of a completed Application within
twenty-one (21) calendar days, CPS Energy may impose a one-time, additional seven (7)
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calendar day extension period in which to complete its review for each Application. CPS
Energy shall provide the Attaching Entity with seven (7) calendar days’ prior notice that
it intends to exercise its option to impose the extension period. Should CPS Energy fail
to take action on the Application within the extension period, all proposed Attachments
or Overlashings included within that specific Application shall be deemed approved,
subject to all then current Applicable Engineering Standards and all other procedural and
operational requirements under these Standards.
a) Review. In making its decision as to whether to approve an Application, CPS Energy
will consider the Applications proposed compliance with engineering and safety
requirements, in accordance with the Applicable Engineering Standards set forth in
Section II.A.4. In addition, CPS Energy shall consider Capacity constraints,
including the future needs of CPS Energy as determined in accordance with the
Reserved Capacity provisions set forth in Section II.H.10, flood zone requirements,
in-flight CPS Energy projects, and other circumstances known at the time that would
directly affect the engineering, safety requirements, and Capacity constraints of the
Application submission and review which may impact the Application, including any
known third-party requests for Attachment to the same Pole as described in Section
IV.B.3.f below.
b) Make-Ready Electrical Construction. In the event that an Attaching Entity’s
proposed Application requires CPS Energy to undertake and complete Make-Ready
Electrical Construction to accommodate the Attaching Entity’s Application, CPS
Energy will review the detailed design documents and the cost estimate for this
Make-Ready Electrical Construction work provided by the Attaching Entity.
Following CPS Energy’s approval of the Make-Ready Electrical Construction design
and review of the estimated Make-Ready Electrical Construction costs, CPS Energy
may, at its discretion, revise the cost estimate to more accurately reflect the
anticipated cost of the work. CPS Energy will then submit this estimate of the cost
of Make-Ready Electrical Construction to the Attaching Entity utilizing the CPS
Energy Authorization for Make-Ready Work form, provided in Appendix B, for
approval from the Attaching Entity to proceed. The Attaching Entity shall approve
the make advanced payment of this cost estimate in order for any Make-Ready
Electrical Construction to procced in accordance with the provisions of Section II.I.3.
The Attaching Entity shall have fifteen (15) calendar days following the issuance of
the CPS Energy invoice for Make-Ready Work to approve the estimate and provide
payment. Failure of the Attaching Entity to respond to CPS Energy or return the CPS
Energy invoice for Make-Ready Work within the fifteen (15) calendar day period
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will result in the Application being cancelled by CPS Energy, with all applicable
Application Fees being non-refundable.
c) Changes Required. If CPS Energy describes any changes, modifications, or revisions
to the proposed Make-Ready Electrical Construction design documents pursuant to
this Section IV.B.3, CPS Energy shall notify the Attaching Entity in writing. Upon
receipt of this notice, the Attaching Entity may notify CPS Energy in writing that it
agrees to the changes, modifications, or revisions to the proposed Make-Ready
Electrical Construction design required by CPS Energy, in which case the Attaching
Entity may resubmit the Application as amended and it shall be deemed granted; or
the Attaching Entity may propose alternative changes, modifications, or revisions
consistent with Applicable Engineering Standards by resubmitting the Application
with such other alternative proposals, provided that such resubmission explains the
reasons for the alternative proposals and addresses all concerns raised by CPS Energy
in response to the initial Application. The alternative proposals shall not be the
original Make-Ready Engineering design documents rejected by CPS Energy.
The Attaching Entity shall incur an Application Fee, if applicable, upon resubmitting
the Application containing the alternative proposals. CPS Energy shall have twenty-
one (21) calendar days of receipt thereof to provide the Attaching Entity with:
(i) Notification that access is granted based on the alternative proposals; or
(ii) A detailed description of any changes, modifications, or revisions to the
alternative proposal necessary to comply with safety, reliability, or generally
applicable engineering practices or standards.
In the event CPS Energy fails to complete its review within twenty-one (21) calendar
days of the resubmitted Application containing the alternative proposals for Make-
Ready Electrical Construction, CPS Energy may impose a one-time additional seven
(7) calendar day extension period in which to complete its review of the resubmitted
Application. CPS Energy shall provide the Attaching Entity with seven (7) calendar
days’ prior notice that it intends to exercise its option to impose the extension period.
Should CPS Energy fail to take action on the resubmitted Application within the
extension period, the alternative proposal shall be deemed approved, subject to all
then current Applicable Engineering Standards and all other procedural and
operational requirements under these Standards.
d) Compliance by Attaching Entity. CPS Energy’s acceptance of the submitted Make-
Ready Electrical Construction design and engineering documents does not relieve the
Attaching Entity from compliance with the requirements of the Texas Engineering
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Act, the National Electrical Safety Code, and all other Applicable Engineering
Standards as required by this Standard.
e) Application Approval.
(i) If Make-Ready Electrical Construction Is Required. After acceptance of all
necessary revisions, CPS Energy will issue to the Attaching Entity the CPS
Energy Authorization for Make-Ready Work, a copy of which is in Appendix
B. The Attaching Entity shall comply with the provisions of Section IV.B.4.
(ii) If Make-Ready Electrical Construction Is Not Required. After acceptance of
all necessary revisions to the Application, CPS Energy will issue to the
Attaching Entity the CPS Energy Notice to Proceed, a copy of which is in
Appendix B. The Attaching Entity shall comply with the provisions of Section
IV.B.4.e.
f) Treatment of Multiple Requests for Same Pole. CPS Energy shall consider complete
Applications received from multiple Attaching Entities to attach to the same Pole on
a “first-come, first-served”, non-discriminatory basis.
(i) If CPS Energy receives a subsequent Application for the same Pole from a
second prospective Attaching Entity following acceptance of a complete
Application and prior to completing Make-Ready Electrical Construction or
issuing a Notice to Proceed on said first Application, CPS Energy shall reject
the second Application and any subsequent Applications for the same Pole
without consideration of the proposed Attachments from the Application which
was first in time. CPS Energy will reconsider the rejected Application if it is
revised and resubmitted to eliminate the conflict with the first in time
Application previously approved. Should the second Application be for a
Wireless Installation, CPS Energy will evaluate the Wireless Installation
Application as if the Attachment of the first Attaching Entity has been
completed.
(ii) Should the first in time Application require CPS Energy to undertake and
complete any Make-Ready Electrical Construction on a Pole with a subsequent
request for an Attachment or Wireless Installation received before CPS Energy
completes such Make-Ready Electrical Construction, CPS Energy shall meet
with each Attaching Entity and allocate the costs to complete this Make-Ready
Electrical Construction evenly between the Attaching Entities requesting access
to the Pole.
(iii) Where Make-Ready Electrical Construction on the Pole with multiple
Attachment and/or Wireless Installation requests arise not required or has been
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already completed; in the event the Attaching Entity that was first in time fails
to timely affix its Attachment or Wireless Installation in accordance with
Section IV.B.4.f or Section V.B.4.f, as applicable, CPS Energy will withdraw
the first Application and process the second Application without consideration
to the initial first-in-time Application.
(iv) CPS Energy will simultaneously consider multiple Applications addressing the
Communications Facilities of separate Attaching Entities provided such
Applications are filed together and each Application includes one common set
of engineering design documents accounting for the Communications Facilities
of all the applicants. In such case, CPS Energy will issue a Permit to each
Attaching Entity that filed an Application and such Permits will be subject to
one set of construction plans to be carried out by joint agreement of the parties
including the cost allocation of all required Make-Ready Work. Such allocation
does not apply to Risers.
4. Make-Ready Electrical Construction. If Make-Ready Electrical Construction is
required to accommodate an Attaching Entity’s Attachment and/or Overlashing, CPS
Energy or its contractors shall perform such work at Attaching Entity’s expense as
provided in Section IV.B.3, Section IV.B.5.e, and Appendix B.
a) Advance Payment. CPS Energy shall invoice Attaching Entity based on the
estimated cost of such work. Pursuant to Sections II.I.3, CPS Energy shall require
payment in advance for any Make-Ready Electrical Construction, to be performed by
CPS Energy or its contractors.
b) Work Performed by CPS Energy or CPS Energy Contractor. Make-Ready Electrical
Construction shall be performed only by CPS Energy and/or a contractor authorized
by CPS Energy to perform such work. Prior to commencement of Make-Ready
Electrical Construction and upon receipt of advance payment, CPS Energy will
schedule a work order within thirty (30) calendar days for construction to commence.
CPS Energy will strive to perform the Make-Ready Electrical Construction to
accommodate an Attaching Entity’s Communications Facilities within sixty (60)
calendar days. CPS Energy shall provide to the Attaching Entity as soon as possible
the estimated schedule for completing the Make-Ready Electrical Construction. In
the event that CPS Energy is unable to complete the Make-Ready Electrical
Construction within the sixty (60) calendar day period, an Attaching Entity may
request in writing to CPS Energy the use of temporary Attachments by submitting a
Request for Temporary Attachment form, a copy of which is available at
www.cpsenergy.com/poleattachments and located in Appendix B. Upon receiving
this written request, CPS Energy shall coordinate with the Attaching Entity on a non-
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discriminatory basis to determine all reasonable means to accommodate the
temporary Attachment request subject to compliance with the Applicable
Engineering Standards.11 Any temporary Attachments must be removed and properly
installed upon the completion of the Make-Ready Electrical Construction. The cost
to install and remove a temporary Attachment shall be borne by the Attaching Entity.
c) Work Schedule. In performing all Make-Ready Electrical Construction to
accommodate an Attaching Entity’s Attachments, CPS Energy will include such
work in its normal work schedule on a non-discriminatory basis. In the event the
Attaching Entity requests that the Make-Ready Electrical Construction be performed
on a priority basis or outside of CPS Energy’s normal work hours, the Attaching
Entity shall pay the appropriate increased costs. Nothing herein shall be construed to
require performance of any Attaching Entity’s work before other scheduled work,
CPS Energy service restoration, or other Emergency work.
d) Notifying Other Attaching Entities. Prior to commencing Make-Ready Electrical
Construction, CPS Energy shall provide no less than ten (10) calendar days’ written
notice to the Attaching Entities on the affected Pole of the impending work. Such
notification will be sent through the National Joint Utilities Notification System
(NJUNS).
e) Notice to Proceed. Following completion of the Make-Ready Electrical
Construction, CPS Energy will issue a CPS Energy Notice to Proceed, a form of
which is provided in Appendix B, to the Attaching Entity (applicant) in writing that
the Pole is available for Make-Ready Communications Construction and Attachment.
When applicable, the Attaching Entity shall proceed to install its Attachments
utilizing the One-Touch Transfer Process described in Section IV.B.5 below.
Whenever the transfer of an Attachment or Wireless Installation would requires
cutting or splicing of the Communication Facility or disruption of wireless service,
the Complex Transfer Process in Section IV.B.6 below shall apply.
f) Failure to Attach. An Attaching Entity must exercise the right granted by the CPS
Energy Notice to Proceed within ninety (90) calendar days of issuance of the Notice
to Proceed. If needed, the Attaching Entity may request in writing to CPS Energy an
additional thirty (30) calendar day extension of the effective period of the Notice to
Proceed. The request for this extension must be received by CPS Energy no later
than seven (7) calendar days before the expiration date provided in the Notice to
Proceed. In considering this request, CPS Energy will review past construction
11 NESC, Rule 013B4 and Rule 014, C2-2017.
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practices of the Attaching Entity and current efforts underway to complete the
installation for which the extension was requested. CPS Energy will provide a written
response to the request for extension within three (3) calendar days of receiving the
request. CPS Energy, at its discretion, may not consider any requests for extension
received within seven (7) calendar days of the expiration of the Notice to Proceed.
(i) Failure to install an Attachment within the effective period of the Notice to
Proceed, or extended period if granted by CPS Energy, will result in expiration
of the Application and the forfeiture of the applicable Application Fees and any
payments made for Make-Ready Work already completed. Following expiration
of an Application, should the Attaching Entity wish to continue to install the
Attachment subject to the expired Application, the Attaching Entity must submit
a new Application covering the same Attachment including all appropriate
Application Fees.
(ii) CPS Energy and the Attaching Entity shall determine a mutually-agreeable
schedule for the completion of the Make-Ready Work should an issue of Force
Majeure, as described in the Pole Attachment Agreement, be asserted by either
party.
5. Make-Ready Communication Construction – One Touch Transfer. The transfer of
third-party Attachments or Wireless Installations, whether conducted by an Attaching
Entity or CPS Energy, shall hereinafter be referred to as the “One-Touch Transfer
Process.” Pursuant to these Standards, the One-Touch Transfer Process allows an
Attaching Entity to transfer or rearrange an Attachment of one or more Attaching Entities
in the Communications Space of a CPS Energy Pole, and coordinate the Joint Meeting
Transfer of a Wireless Installation, as may be necessary to accommodate the installation
of a new Attachment contingent upon compliance with requirements identified in this
Section IV.B.5. All One-Touch Transfers conducted by an Attaching Entity or CPS
Energy must comply with the following requirements:
a) Simple Transfers Only. One-Touch Transfers shall be limited to rearrangement or
transfer of third-party Attachments on an existing Pole and/or a Mid-span Installation
suspended by a Messenger cable between two Poles. Such Attachment or Mid-span
installation may be rearranged within an existing Pole or transferred onto a
replacement Pole Installation (along with any supporting Communication Facility or
Overlash) is not subject to cutting and splicing and any affected Mid-span Installation
is not severed from the Communication Facility providing connectivity.
b) Joint Meeting Transfer. Any Wireless Installation on a Pole hosting Attachments
subject to One-Touch Transfer shall be modified within the same Pole or transferred
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onto a replacement Pole at the same time as the Attachments subject to Simple
Transfer through the coordination of a Joint Meeting Transfer of the Wireless
Installation.
(i) Before an Attaching Entity seeking to avail itself of the One-Touch Transfer
process begins to undertake Make-Ready Communication Construction, it shall,
not less than twenty-one (21) calendar days before the date contemplated for the
start of Make-Ready Communication Construction, notify in writing each
affected existing Attaching Entity owning a Wireless Installation on the affected
Pole and arrange for a Joint Meeting Transfer of the Wireless Installation.
(ii) Such notice shall identify the specific Pole subject to Simple Transfer where the
Wireless Installation is mounted. The written notice shall provide sufficient
instructions to coordinate the Joint Meeting Transfer.
(iii)Either party may make earlier arrangements with the other for any proposed Joint
Meeting Transfer. Both Attaching Entities have an obligation to cooperate to
successfully complete the Joint Meeting Transfer of the Wireless Installation. In
the event the Attaching Entity utilizing the One-Touch Transfer Process fails to
provide the required notice of the Joint Meeting Transfer to the Attaching Entity
that owns the Wireless Installation, the former will be responsible for the cost of
removing and relocating the Wireless Installation to a replacement Pole.
(iv) In the event the Attaching Entity that owns the Wireless Installation fails to attend
the Joint Meeting Transfer or attends the meeting but fails to relocate the Wireless
Installation as part of the One-Touch Transfer Process, such Attaching Entity
shall be responsible for modifying the Wireless Installation within the same Pole
or transferring the Wireless Installation onto a replacement Pole within ten (10)
calendar days following the date of the failed Joint Meeting Transfer. Such
failure to relocate the Wireless Installation within such ten (10) day period shall
result in CPS Energy finding the Wireless Installation in non-compliance with
these Standards subject to a penalty as provided in Appendix H. In addition, such
Attaching Entity shall be responsible for the cost of removing the original Pole
should a replacement Pole be required to be installed as part of the One-Touch
Transfer Process.
c) Certified Contractors. An Attaching Entity must engage qualified contractors
approved by CPS Energy pursuant to a contractor approval program developed by
CPS Energy with the input of Attaching Entities.
d) Applicability to CPS Energy. CPS Energy’s communications wires or facilities
installed in the Communication Worker Safety Zone of a Pole will also be subject to
the One-Touch Transfer Process.
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e) One-Touch Transfers Subject to Applicable Engineering Standards. All Make-Ready
Communication Construction performed under the One-Touch Transfer Process shall
meet all Applicable Engineering Standards, including CPS Energy’s clearance
standards. Applications that include Make-Ready Communications Construction and
One-Touch Transfers that fail to meet Applicable Engineering Standards will be
rejected by CPS Energy.
f) Cost Responsibility. With the exception of instances where in the sole judgement of
CPS Energy, a Pole has been identified as defective, CPS Energy will be responsible
for the cost to replace such defective Pole. In all other instances, the Attaching Entity
shall pay all costs of Make-Ready Electrical Construction and Make-Ready
Communications Construction associated with One-Touch Transfers as described
below:
(i) Where the Pole includes one or more third-party Attachment(s) that fail to meet
Applicable Engineering Standards but otherwise there is enough space on the
Pole to accommodate the Attaching Entity’s Attachment, Make-Ready Work will
not include the transfer of the third-party Attachment(s), unless the lowest
Attachment on the Pole fails to meet NESC clearance standards and/or poses a
public safety hazard. In that case, Make-Ready Work will include the relocation
of the non-compliant Attachment and the Attaching Entity may recover the cost
to bring such Attachment into compliance from the owner of the non-complaint
Attachment.
(ii) Where the Pole includes one or more third-party Attachment(s) that fail to meet
Applicable Engineering Standards, and in order to accommodate the Attaching
Entity’s Attachment on the same Pole the third-party Attachment(s) must be
rearranged, the cost of rearranging the third-party Attachment(s) will be included
in Make Ready Work. Provided that if the lowest Attachment on the Pole fails to
meet NESC clearance standards and/or poses a public safety hazard, the
Attaching Entity may recover the cost to bring such Attachment into compliance
from the owner of that Attachment, but no others.
(iii)Where the Pole includes one or more third-Party Attachment(s) that fail to meet
Applicable Engineering Standards, and in order to accommodate the Attaching
Entity’s Attachment a new Pole must be installed, the cost of the new Pole and
the transfer of the third-party Attachment(s) will be included in the Make-Ready
Work.
(iv) Where the Pole includes one or more third-party Attachment(s) that meet
Applicable Engineering Standards, and otherwise there is enough space on the
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Pole to accommodate the Attaching Entity’s Attachment, Make-Ready Work will
not include the transfer of the third-party Attachment(s).
(v) Where the Pole includes one or more third-party Attachment(s) that comply with
Applicable Engineering Standards, and in order to accommodate the Attaching
Entity’s Attachment on the same Pole the third-party Attachment(s) must be
rearranged, the cost of rearranging the third-party Attachment(s) will be included
in Make-Ready Work.
(vi) Where the Pole includes one or more third-party Attachment(s) that comply with
Applicable Engineering Standards, and in order to accommodate the Attaching
Entity’s Attachment a new Pole must be installed, the cost of the new Pole and
the transfer of the third-party Attachment(s) will be included in Make-Ready
Work.
g) Notice of Transfer. An Attaching Entity shall provide all third-parties having wire
Attachments or Overlashings affected by a proposed One-Touch Transfer with
advanced written notice of such One-Touch Transfer no less than twenty-one (21)
calendar days prior to undertaking such One-Touch Transfer. This notice shall be
provided using the NJUNS to a duly designated representative of the affected
Attaching Entity, unless another method of notice is prescribed by CPS Energy. The
Attaching Entity who desires to utilize the One-Touch Transfer Process shall bear the
responsibility of determining the appropriate representative for each Attaching Entity
affected by the Attaching Entity’s implementation of the One-Touch Transfer
Process.
h) Critical Communication Facilities. If an affected Attaching Entity, in its reasonable
discretion, determines that a proposed One-Touch Simple Transfer poses a risk of
disconnection or interruption of service to a Critical Communications Facility, the
affected Attaching Entity shall notify the requesting Attaching Entity and CPS
Energy in writing within ten (10) calendar days of receiving the notice of transfer
described in Section IV.5.g. The affected Attaching Entity is obligated to make the
requested transfer of their Critical Communication Facilities within fifteen (15)
calendar days of providing such notice. Failure to transfer the Critical
Communications Facilities in a timely manner will subject the Critical
Communications Facility to the One-Touch Transfer Process.
i) Post-Transfer Notice. Within fifteen (15) calendar days following the completion of
a One-Touch Transfer, the Attaching Entity shall send written notice of the One-
Touch Transfer and as-built reports to each affected Attaching Entity. Within thirty
(30) calendar days of receipt of these as-built reports, the Attaching Entity that owns
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the Communications Facilities that were transferred or relocated may conduct an
inspection at the expense of the Attaching Entity who moved the facilities. If the One-
Touch Transfer failed to meet all Applicable Engineering Standards, the owner of the
Communications Facilities subject to transfer or relocation will notify the Attaching
Entity responsible for the One-Touch Transfer of any deficiency, which will be
corrected within fifteen (15) calendar days following receipt of such written notice at
the expense of the Attaching Entity responsible for the One-Touch Transfer. The
Attaching Entity responsible for the One-Touch Transfer shall pay the actual,
reasonable, and documented inspection expenses incurred by the owner of the
Communication Facilities subject to transfer or relocated, within forty-five (45)
calendar days of receipt of an invoice. Failure of the owner of the moved or relocated
Attachment to undertake and complete the inspection within the thirty (30) calendar
day period shall be deemed acceptance of the One-Touch Transfer.
j) Attaching Entity’s Attachments Subject to One-Touch Transfer by Other Entities.
An Attaching Entity’s Communications Facilities shall be subject to the One-Touch
Transfer Process conducted by another Attaching Entity or CPS Energy pursuant to
the same terms and conditions prescribed in this Section IV.B.5 and the daily penalty
found in Appendix H for failure to timely relocate a Wireless Installation.
6. Make-Ready Communication Construction - Complex Transfers.
a) Responsibility for Complex Transfers. The accomplishment of a Complex Transfer
is considered part of Make-Ready Communication Construction and shall be
performed by the Attaching Entity which owns the Attachment subject to transfer. It
is the responsibility of the Attaching Entity requesting the Complex Transfer to
negotiate a private process with the owning Attaching Entity for the Complex
Transfer. The cost of the Complex Transfer shall be borne by the requesting
Attaching Entity. Wireless Installations will not be subject to the Complex Transfer
process as any modification or transfer of such facilities shall be subject to the Joint
Meeting Transfer process described in Section IV.B.5.b.
b) Complex Transfers Escalation Process. In the event an Attaching Entity refuses to
reach agreement on a process for the expedient transfer of an Attachment subject to
a Complex Transfer, the requesting Attaching Entity may rely on the following
escalation procedures. At any time during these escalation procedures, the requesting
Attaching Entity and the owner of the Attachment subject to the Complex Transfer
may reach agreement on a voluntary transfer process. In such event, the requesting
Attaching Entity shall notify CPS Energy in writing of this agreement.
(i) Level 1: Initial Request for Complex Transfer (Days 0 to 30)
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a. Initial Notice Letter. The requesting Attaching Entity shall provide written
notice to owner of the Attachment subject to Complex Transfer requesting the
transfer of such Attachment using NJUNS with a copy to CPS Energy. The
Attaching Entity which owns such Attachment shall perform the transfer
within thirty (30) calendar days of receipt of notice from the requesting
Attaching Entity.
(ii) Level 2: Initial Escalation Process (Days 31 to 60)
a. Escalation Notification. If the owner fails to transfer the Attachment subject
to Complex Transfer within the initial thirty (30) calendar days, the requesting
Attaching Entity shall send a certified letter notifying the non-compliant
Attaching Entity that failure to transfer the Attachment within a subsequent
thirty (30) calendar days (escalation period) of receipt of notice will result in
the Attachment in question being designated by CPS Energy as non-
compliant with the Complex Transfer Process and subject to penalty, as
described in Appendix H, on the basis of interference with the requesting
Attaching Entity’s permitted Attachment rights. The requesting Attaching
Entity shall send CPS Energy a copy of the escalation letter and all other
correspondence between the parties related to this matter.
b. Duty to Negotiate. The requesting Attaching Entity is required to continue
negotiations with the non-compliant Attaching Entity during the thirty (30)
calendar day escalation period. Absent extraordinary circumstances, the non-
compliant Attaching Entity’s failure to transfer the Attachment subject to
Complex Transfer by the end of the thirty (30) calendar day escalation period
shall be considered a lack of cooperation on the part of the non-compliant
Attaching Entity. Conversely, absent extraordinary circumstances, a refusal
by the requesting Attaching Entity to agree to an alternative process for the
transfer of the Attachment in question within a reasonable date certain shall
be considered a lack of cooperation on the part of the requesting Attaching
Entity.
c. Notice of Success Complex Transfer. If the non-compliant Attaching Entity
transfers the Attachment subject to Complex Transfer within the thirty (30)
calendar day escalation period, or the requesting Attaching Entity transfers
the Attachment by mutual agreement of the parties, no further escalation will
be necessary.
(iii) Level 3: CPS Energy Finding of Non-Compliant Attachments (Days 61 to 90)
a. Request for Finding of Non-compliant Attachments. If the requesting
Attaching Entity and the non-compliant Attaching Entity cannot reach
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agreement and the non-compliant Attaching Entity fails to transfer the
Attachment subject to Complex Transfer within the thirty (30) calendar day
escalation period; the requesting Attaching Entity within five (5) calendar
days thereafter shall notify CPS Energy in writing, provide a short summary
of efforts to negotiate the rearrangement or transfer of the Attachment in
question, and request CPS Energy to make a finding of Non-complaint
Attachment on the basis of interference with the requesting Attaching Entity’s
permitted Attachment rights. The request shall explain why the requesting
Attaching Entity believes the non-compliant Attaching Entity is acting in bad
faith.
b. Notification of Non-Compliant Attachments. Within ten (10) calendar days
of receiving the request for a finding of non-compliant Attachments, CPS
Energy will evaluate the request and if it finds the request credible; CPS
Energy will:
(1) Notify the non-compliant Attaching Entity by certified mail that
CPS Energy has determined the Attachment subject to Complex
Transfer is declared as “Non-compliant Attachment”;
(2) The non-conforming Attaching Entity will begin accruing
penalties as provided in Appendix H of these Standards until the
Non-compliant Attachment is transferred; and
(3) CPS Energy will suspend the processing of the non-compliant
Attaching Entity’s Applications effective five (5) days after
receipt of the certified letter.
Thereafter, the non-compliant Attaching Entity will have fifteen (15) days
in which to transfer the non-compliant Attachment and notify CPS Energy
in writing in order to reinstate the processing of Applications. If the non-
compliant Attaching Entity fails to transfer the non-compliant Attachment
within the twenty (20) calendar day grace period, the non-compliant
Attachment will be subject to further penalties and transfer as provided in
Section III.E and Appendix H. CPS Energy will reinstate the processing
of the non-compliant Attaching Entity’s Applications upon receipt of
written notification of the transfer of the non-compliant Attachment and
the payment of all assessed penalties.
c. Duty to Negotiate. The requesting Attaching Entity is required to continue
negotiations with the non-compliant Attaching Entity which owns the non-
compliant Attachment during the twenty (20) calendar day grace period.
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d. Notice of Transfer. If the non-compliant Attaching Entity transfers the non-
compliant Attachment within the twenty (20) calendar day grace period, or
the requesting Attaching Entity transfers the non-compliant Attachment by
mutual agreement of the parties, the moving party shall notify CPS Energy by
electronic message, and CPS Energy shall reinstate processing of the non-
compliant Attaching Entity’s Applications within twenty-four (24) hours of
receiving payment of all outstanding penalties.
e. Stop Processing Pole Attachment Permit Applications. If CPS Energy does
not receive written notification of the transfer of the non-compliant
Attachment by the end of the twenty (20) calendar day grace period, CPS
Energy shall stop processing the non-compliant Attaching Entity’s
Applications pending further written notice of a successful transfer and the
payment of all outstanding penalties.
(iv) Level 4: Transfer or Removal of Unauthorized Attachments (Days 91 and
Beyond)
a. Notification of Failed Transfer. If the parties fail to negotiate the successful
transfer of the non-compliant Attachment, the requesting Attaching Entity
shall promptly notify CPS Energy in writing of the failed attempt and explain
the reasons for the unsuccessful transfer.
b. Notification of Transfer of Non-compliant Attachments. Following receipt of
the notification of failed transfer, CPS Energy shall promptly proceed to
transfer the non-compliant Attachment at the respective owner’s
expense. Following the transfer of the non-compliant Attachment, CPS
Energy will provide written notification of the transfer to the non-compliant
Attaching Entity within twenty-four (24) hours. CPS Energy shall reinstate
processing of the non-compliant Attaching Entity’s Applications within
twenty-four (24) hours of receiving payment for the transfer cost and all
outstanding penalties.
c. Notice of Transfer. In the event the non-compliant Attaching Entity transfers
the non-compliant Attachment, or the requesting Attaching Entity transfers
the non-compliant Attachment by mutual agreement of the parties, prior to
CPS Energy’s transfer efforts, the moving party shall notify CPS Energy in
writing. The non-compliant Attaching Entity shall be assessed a one-time
fine as provided in Appendix H of these Standards. Thereafter, CPS Energy
shall reinstate the processing of the non-compliant Attaching Entity’s
Applications within twenty-four (24) hours of receiving payment of all
outstanding penalties.
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7. Notice of Attachment Completion and Acceptance.
The Attaching Entity shall notify CPS Energy in writing by submitting the Completion
of Attaching Entity Construction form, a copy of which is available at
www.cpsenergy.com/poleattachments and in Appendix B, within ten (10) calendar days
following the acceptance by all Attaching Entities whose facilities were rearranged or
transferred pursuant to Section IV.B.5 (Simple Transfers) and/or Section IV.B.6
(Complex Transfers) that all Make-Ready Communication Construction has been
completed and accepted, and that the new Attachments and/or Overlashings and all
Make-Ready Work are ready for CPS Energy to undertake Post-Construction Inspection.
8. Post-Construction Inspection.
a) Construction Subject to Inspection. CPS Energy shall complete a Post-Construction
Inspection of applicable Make-Ready Work at the Attaching Entity’s expense within
thirty (30) calendar days of receiving the Attaching Entity’s notification set forth in
Section IV.B.7. CPS Energy will conduct the Post-Construction Inspections to
evaluate compliance with the requested Permit, Applicable Engineering Standards,
or other design and installation requirements. Completion of a Post-Construction
Inspection by CPS Energy shall not in any way relieve any Attaching Entity or an
Attaching Entity’s insurers of any responsibility, duty, obligation, or liability under
these Standards, any contractual agreement, or otherwise; nor does CPS Energy’s
ability to make Post-Construction Inspections relieve an Attaching Entity from its
obligations to exercise due care in the installation of its Attachments or Overlashings.
The Post-Construction Inspection provision set forth in this Section IV.B.8.a does not
affect any other inspection requirements elsewhere in these Standards. This section
IV.B.8 also applies to supplemental Post-Construction Inspections where the
Attaching Entity reports “final corrections” of previously identified non-compliant
work or locations as described in Section IV.B.8.b below.
b) Compliance. In the event a Post-Construction Inspection conducted pursuant to
Section IV.B.8.a reveals that corrections or other actions are required of an Attaching
Entity, including without limitation those required for reasons of safety or structural
integrity, the Attaching Entity shall make such required corrections or take the
requested actions within thirty (30) calendar days after the date CPS Energy sends
written notice. If CPS Energy determines in its reasonable judgment and discretion
that the needed corrections rise to the level of an Emergency, CPS Energy may
perform the necessary corrective work without providing notice, at the Attaching
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Entity’s sole risk and cost plus ten-percent (10%). As soon as practicable thereafter,
CPS Energy will advise the Attaching Entity of the work performed or the action
taken.
c) Issuance of Permit. Upon satisfactory completion of the Post-Construction
Inspection, CPS Energy shall notify the Attaching Entity in writing that CPS Energy
has approved the Attachments identified in the Application by submitting to the
Attaching Entity a Permit, a copy of which form is located in Appendix B, for the
affected facilities.
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C. Private Network Process
A high-level workflow of the Private Network Process for wire Attachments to CPS
Energy Poles is illustrated in the Figure C below.
1. Eligibility. Any private entity or public organization, such as a school, university, or
unit of local government that is an Attaching Entity, not engaged in providing
competitive telecommunication services that operates an internal private network for its
own private non-commercial communications purposes.
2. Application for Permit Required. An Attaching Entity who qualifies for the Private
Network Process may choose either:
a) CPS Energy to Perform Make-Ready Engineering. The Attaching Entity may request
CPS Energy to undertake and complete the Make-Ready Engineering required by the
Application request. If the Attaching Entity elects for CPS Energy to perform the
Make-Ready Engineering, CPS Energy shall provide the Attaching Entity an
estimated cost to prepare and complete the Make-Ready Engineering before starting
the project. Upon approval to proceed, CPS Energy will respond to such Application
requests as promptly as is reasonable, with a goal of providing a response within forty-
five (45) calendar days of receipt of the Application. The Attaching Entity is still
required to submit an Application and pay all applicable Applications Fees as
described in Appendix H. CPS Energy will invoice the Attaching Entity for the cost
to produce the Make-Ready Work in accordance with the provisions of Section II.I.3;
or
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b) Attaching Entity to Perform Make-Ready Engineering. The Attaching Entity may
choose to complete its own Make-Ready Engineering by complying with all
provisions of the Standard Process as described in Section IV.B.
3. CPS Energy Review of Application.
a) CPS Energy to Perform Make-Ready Engineering. If the Attaching Entity chooses
to have CPS Energy complete the Make-Ready Engineering pursuant to Section
IV.C.2.a, then CPS shall respond to the Application within forty-five (45) calendar
days of receipt and provide the Attaching Entity with a detailed description of the
proposed Make-Ready Work required for reasons of safety, reliability, or generally
applicable engineering purposes.
b) Attaching Entity to Perform Make-Ready Engineering. If the Attaching Entity
chooses to be responsible for its own Make-Ready Engineering pursuant to Section
IV.C.2.b, then all provisions of Section IV.B.3 shall be applicable to CPS Energy’s
Review of Applications for Applications considered under the Standard Process –
Small Entity process.
4. Make-Ready Electrical Construction. All provisions of Section IV.B.4 shall be
applicable to Make-Ready Work Electrical Construction for Applications considered
under the Private Network Process.
5. Make-Ready Communication Construction – One Touch Transfers. All provisions
of Section IV.B.5 shall be applicable to Make-Ready Communications Construction for
Applications considered under the Private Network Process regarding One-Touch
Transfers.
6. Make-Ready Communication Construction - Complex Transfers. All provisions of
Section IV.B.6 shall be applicable to Make-Ready Communications Construction for
Applications considered under the Private Network Process regarding Complex
Transfers.
7. Notice of Attachment Completion and Acceptance. All provisions of Section IV.B.7
shall be applicable to Notice of Attachment Completion and Acceptance for Applications
considered under the Private Network Process.
8. Post Construction Inspection. All provisions of Section IV.B.8 shall be applicable to
Post Construction Inspection for Applications considered under the Private Network
Process.
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D. Competitive Provider – Area Wide Network Deployment Process
A high-level workflow of the Competitive Provider – Area Wide Network Deployment
Process for wire Attachments to CPS Energy Poles is illustrated in the Figure D below.
1. Eligibility. An Attaching Entity that is a Competitive Providers with a valid Pole
Attachment Agreement who is engaged in an Area Wide Network Deployment and has
provided CPS Energy a Deployment Plan which contemplates an estimated eighty (80)
or more Pole replacements per month during the majority of the Development Plan period
shall be required to comply with the Competitive Provider – Area Wide Network
Deployment Process.
2. Application for Permit Required. All provisions of Section IV.B.2 shall be applicable
for Applications considered under the Competitive Provider – Area Wide Network
Deployment Process.
3. CPS Energy Review of Application. All provisions of Section IV.B.3 shall be
applicable for CPS Energy’s Review of Applications considered under the Competitive
Provider – Area Wide Network Deployment Process.
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4. Make-Ready Electrical Construction. An Attaching Entity that qualifies for the
Competitive Provider – Area Wide Network Deployment Process per Section IV.D.1
above will be authorized by CPS Energy to perform all necessary Make-Ready Work,
including Make-Ready Electrical Construction using contractors approved by CPS
Energy to perform such work, contingent upon the Attaching Entity entering into a
construction contract with CPS Energy. Pursuant to this Section IV.D.4, the Attaching
Entity shall be responsible for obtaining all materials and work at Attaching Entity’s risk
and expense for all Make-Ready Electrical Construction, except as provided in Section
IV.B.5.f.
a) Construction Completion Time. The Attaching Entity shall complete Make-Ready
Electrical Construction within sixty (60) calendar days of receiving CPS Energy’s
approval of an Application. Should the Attaching Entity fail to complete Make-
Ready Electrical Construction within the sixty (60) calendar period following the
approval of the Application, CPS shall consider the Application cancelled.
(i) For the initial stages of a Network Deployment Process project, the time required
to start Make-Ready Electrical Construction may be extended by CPS Energy up-
to one hundred twenty (120) calendar days to allow for an efficient ramp-up
transition during the initial six (6) months of the Network Deployment project.
(ii) To qualify for this extension, the Attaching Entity must provide CPS Energy a
written request for extension and a construction schedule for the first six (6)
months of the project. After reviewing this schedule, CPS Energy will provide
written notice that the extension is either approved, rejected, or modified,
including CPS Energy’s rationale for such decision. If CPS Energy rejects or
modifies the extension request, CPS Energy will call for a meeting with the
Attaching Entity to discuss the extension and strive to reach agreement.
b) Workmanship. All of the Attaching Entity’s Make-Ready Electrical Construction
shall be performed at the Attaching Entity’s sole cost and expense, shall be installed
in a good and workmanlike manner, and must not adversely affect the structural
integrity of CPS Energy’s Poles, CPS Energy Facilities, or the Communication
Facilities of other Attaching Entities attached thereto. All such Make-Ready
Electrical Construction work is subject to inspection and/or observation by CPS
Energy or its designee at any time as further described in these Standards and in the
Construction Agreement.
c) Operational Procedures. After reviewing the Deployment Plan and at any time during
the deployment project, CPS Energy and the Attaching Entity shall develop a set of
mutually agreeable operational procedures addressing items such as, but not limited
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to: customer outage notifications, contractor crew work location notifications,
contractor safety reporting, material procurement, customer complaints, or other
operational needs specific to the Attaching Entity’s Deployment Plan. These
operational procedures shall include provisions for updating, enforcement, and
conflict resolution as required.
d) Qualified Employees. All of the Attaching Entity’s Make-Ready Electrical
Construction performed on CPS Energy’s Poles, and/or in the vicinity of other CPS
Energy Facilities shall be in compliance with all provisions of the Construction
Contract referenced in this Section IV.D.4. The Attaching Entity shall assure and
certify to CPS Energy that any person working in the Electric or Supply Space on
Poles, and/or CPS Energy Facilities is fully qualified to undertake and complete the
work contemplated and is familiar with all Applicable Engineering Standards
including all provisions of these Standards and the Construction Contract.
e) Multiple Requests for Pole. In the event multiple Attaching Entities have been
granted Permits to access the same Pole, the applicable provisions of Section IV.B.3.f
shall apply. However, should a disagreement exist between the Attaching Entities
as to construction and installation schedules; CPS Energy shall require a
representative of each Attaching Entity who has authority to agree on these issues to
attend a meeting called by CPS Energy to discuss and attempt to reach agreement on
this dispute. In the event the Attaching Entities are unable to so agree, then the
applicable provisions of Section II.L shall apply.
f) Construction Scheduling. Before beginning Make-Ready Electrical Construction on
a Pole, or series of Poles; CPS Energy and the Attaching Entity shall develop a
mutually agreed construction schedule and methodology providing for notice of the
Pole locations, proposed dates on which work will commence and finish, and whether
any electrical service interruptions or de-energizations will be required. CPS Energy
approval is required for all outages, such approval not to be unreasonably withheld,
conditioned or delayed; contingent upon the reliability needs of the CPS Energy
electric system.
THE ATTACHING ENTITY SHALL INDEMNIFY AND HOLD HARMLESS
CPS ENERGY AND ITS TRUSTEES, OFFICERS, EMPLOYEES, AGENTS,
CONTRACTORS, AND REPRESENTATIVES FROM ALL CLAIMS FOR
LOSS, HARM, PROPERTY DAMAGE, AND BODILY INJURY OR DEATH
IN CONNECTION WITH ANY WORK PEFORMED IN CONNECTION
WITH THESE STANDARDS.
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g) Materials. The Attaching Entity shall furnish all necessary materials and hardware
including but not limited to: Poles, crossarms, mounting hardware, guys, anchors,
insulators, conductors, and any associated miscellaneous hardware necessary to
complete the Make-Ready Electrical Construction in compliance with the Applicable
Engineering Standards and the construction contract between the parties. CPS
Energy shall provide any required transformers and other special equipment to be
identified in said construction contract. All materials to be provided by and used by
the Attaching Entity for Make-Ready Electrical Construction on CPS Energy Poles
and other facilities shall be obtained from vendors approved by CPS Energy and shall
be new and of good quality, free from known material defects, and shall comply with
all applicable CPS Energy specifications. CPS Energy shall not unreasonably
withhold, delay or condition its approval of a vendor.
All materials obtained by the Attaching Entity will be subject to an additional quality
check to be performed by the Attaching Entity at the site, prior to use. At CPS
Energy’s option, all materials obtained by Attaching Entity shall be subject to
inspection by CPS Energy on reasonable notice to the Attaching Entity; provided that
such inspection will be completed in accordance with the Attaching Entity’s
construction schedule, discussed in Section IV.D.4.f, and will not unreasonably delay
such schedule.
h) CPS Energy Property. All Poles, materials, and other equipment installed as part of
the Make-Ready Electrical Construction under this Area Wide Network Deployment
Process, with the exception of Communication Facilities installed by the Attaching
Entity for use in its provision of services, shall become and remain CPS Energy’s
sole property, regardless of which entity procured, installed, or paid for it. The
Attaching Entity shall execute any documents reasonably requested by CPS Energy
to evidence the transfer of title to such Poles, materials, and equipment to CPS
Energy, and the Attaching Entity shall brand and tag all new Poles to indicate CPS
Energy ownership.
The Attaching Entity’s performance of Make-Ready Electrical Construction or
payment of any costs associated with such work:
• Shall in no way create or vest in the Attaching Entity any
ownership right, title, or interest in any Pole or electrical
facilities;
• Shall not entitle the Attaching Entity to any offsets, credits,
payments, or income from CPS Energy’s operation of the Pole
or facilities;
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• Alter or affect CPS's rights under these Standards; or
▪ Restrict CPS Energy’s ability to allow access to other Attaching
Entities in accordance with these Standards.
i) Disposal/Salvage of Materials. CPS Energy will provide a list of all equipment
and/or materials which the Attaching Entity may remove from service as a result of
undertaking and completing Make-Ready Electrical Construction pursuant to this
Section IV.D.4 which CPS Energy requires to either be salvaged by CPS Energy or
disposed of by the Attaching Entity at Attaching Entity’s expense. Equipment and/or
materials that are to be salvaged or recycled by CPS Energy are to be delivered at a
place determined by CPS Energy. All equipment and/or materials which are to be
disposed of by the Attaching Entity shall be handled in a manner consistent with all
applicable federal, state, and local laws, rules, and regulations. Copies of all
applicable disposal manifests shall be provided to CPS Energy on a monthly basis
during the course of the Attaching Entity’s performance of Make-Ready Electrical
Construction.
j) Notification to CPS Energy. Following the Attaching Entity’s completion of Make-
Ready Electrical Construction, the Attaching Entity will promptly notify CPS Energy
in writing by submitting the Completion of Attaching Entity Construction form, a
copy of which is available at www.cpsenergy.com/poleattachments and in Appendix
B, within five (5) calendar days from completion of the Make-Ready Electrical
Construction.
k) Make-Ready Electrical Construction Inspection. CPS Energy shall inspect, at
Attaching Entity’s expense, Attaching Entity’s Make-Ready Electrical Construction
at any time, but no later than thirty (30) calendar days following receipt of the
Attaching Entity’s notification set forth in Section IV.D.4.i. CPS Energy will conduct
these inspections to evaluate compliance with the Application’s design and
installation requirements and evaluate compliance with the Applicable Engineering
Standards and the construction contract between the parties. The completion of an
inspection by CPS Energy shall not operate in any way to relieve Attaching Entity,
its contractors, or its insurers of any responsibility, duty, obligation, or liability under
these Standards, any contractual agreement, or otherwise; nor does CPS Energy’s
ability to make inspections relieve the Attaching Entity from its obligations to
exercise due care in the completion of Make-Ready Electrical Construction. The
inspection right set forth in this Section IV.D.4.j does not affect any other inspection
rights afforded CPS Energy under these Standards and as Pole owner.
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l) Corrective Action. In the event an inspection conducted pursuant to Section IV.D.4.j
reveals that corrections or other actions are required of the Attaching Entity,
including without limitation those required for reasons of safety or structural
integrity, the Attaching Entity shall make such required corrections or take the
requested actions within fifteen (15) calendar days after the date CPS Energy sends
written notice. If CPS Energy determines in its reasonable judgment and discretion
that the needed corrections rise to the level of an Emergency, CPS Energy may
perform the corrective work without providing notice, at the Attaching Entity’s sole
cost and risk plus ten-percent (10%).
m) Notice to Proceed. Following approval of the Make-Ready Electrical Construction,
CPS Energy will issue a CPS Energy Notice to Proceed, a form of which is provided
in Appendix B, to the Attaching Entity (applicant) in writing that the Pole(s) is
available for Make-Ready Communications Construction and Attachment. When
applicable, the Attaching Entity shall proceed to install its Attachments utilizing the
One-Touch Transfer Process described in Section IV.B.5. Whenever the transfer of
an Attachment or Wireless Installation would requires cutting or splicing of the
Communication Facility or disruption of wireless service, the Complex Transfer
Process in Section IV.B.6 shall apply.
n) Failure to Attach. An Attaching Entity must exercise the right granted by the CPS
Energy Notice to Proceed within ninety (90) calendar days of issuance. If needed,
the Attaching Entity may request in writing to CPS Energy an additional thirty (30)
calendar day extension of the effective period of the Notice to Proceed. The request
for this extension must be received by CPS Energy no later than seven (7) calendar
days before the expiration date provided in the Notice to Proceed. In considering this
request, CPS Energy will review past construction practices of the Attaching Entity
and current efforts underway to complete the installation for which the extension is
requested. CPS Energy will provide a written response to the request for extension
within three (3) calendar days of receipt. CPS Energy, at its discretion, may deny
any requests for extension received within seven (7) calendar days of the expiration
of the Notice to Proceed.
5. Make-Ready Communication Construction – One Touch Transfer. All provisions of
Section IV.B.5 shall be applicable to Make-Ready Communications Construction for
Applications considered under the Competitive Provider – Area Wide Network
Deployment Process regarding One-Touch Transfers.
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6. Make-Ready Communication Construction - Complex Transfers. All provisions of
Section IV.B.6 shall be applicable to Make-Ready Communications Construction for
Applications considered under the Competitive Provider – Area Wide Network
Deployment Process regarding Complex Transfers.
7. Notice of Attachment Completion and Acceptance. All provisions of Section IV.B.7
shall be applicable to Notice of Attachment Completion and Acceptance for Applications
considered under the Competitive Provider – Area Wide Network Deployment Process.
8. Post Construction Inspection. All provisions of Section IV.B.8 shall be applicable to
Post Construction Inspection for Applications considered under the Competitive Provider
– Area Wide Network Deployment Process.
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E. Competitive Provider – Network Upgrade Process
1. Eligibility. An Attaching Entity that is a Competitive Provider with a valid Pole
Attachment Agreement who is engaged in a significant network upgrade and has
provided CPS Energy with a Deployment Plan shall be required to comply with the
Competitive Provider – Network Upgrade Process (Network Upgrade Process).
2. Choice of Process. Attaching Entities who qualifying to install Attachments under the
Network Upgrade Process shall be provided the choice of either:
a) Choose to have CPS Energy complete the Make-Ready Electrical Construction;
thereby the Attaching Entity shall operate under the Competitive Provider – Standard
Process for Attachments as described in Section IV.B; or
b) Choose to be responsible for the Make-Ready Electrical Construction; thereby the
Attaching Entity shall operate under the Competitive Provider – Area Wide Network
Deployment Process for Attachments as described in Section IV.D.
3. Written Notice of Choice. The Attaching Entity qualifying for the Network Upgrade
Process shall provide CPS Energy written notice of its decision pursuant to Section
IV.E.2 as soon as practical, but no less than three (3) months before submitting the first
Application as part of its Deployment Plan. The Attaching Entity’ choice of process will
be irrevocable during the period as specified in the Deployment Plan provided the
Attaching Entity remains qualified for the Network Upgrade Process per Section IV.E.1.
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F. Competitive Provider – Standard Process for Overlashing Existing
Attachments
1. Eligibility. Default process for any Attaching Entity with a valid Pole Attachment
Agreement that is a Competitive Provider engaged in Overlashing existing Attachments.
2. Application for Permit Required. All provisions of Section IV.B.2 shall be applicable
to Applications considered under the Competitive Provider – Standard Process for
Overlashing Existing Attachments, except as provided below:
a) An Attaching Entity may Overlash its own Attachments where the facilities
comprising the Overlashing and Attachment do not exceed a combined total of three
and one-half inches (3.5”) in diameter, such Overlashing fully complies with the
Applicable Engineering Standards, and no Make-Ready Electrical Construction is
required. In such cases, the Attaching Entity shall provide CPS Energy with five (5)
calendar days’ prior written notice of the Overlashing and its compliance with the
requirements set forth in this Section IV.F.2.a.
b) For Overlashing and Attachments that will exceed a combined total of three and one-
half inches (3.5”) in diameter, CPS Energy requires ten (10) calendar days’ notice
before installation and its compliance with the requirements set forth in Section
IV.F.2.a.
c) An Attaching Entity shall be permitted to Overlash its own Attachments without prior
written notice or submitting an Application to CPS Energy in the event such
Overlashing is necessary to restore service temporarily to the Attaching Entity’s
customers and is in compliance with the Applicable Engineering Standards. In such
cases, the Attaching Entity shall provide CPS Energy with written notice of the
Overlashing with ten (10) calendar days of its completion.
d) Such notice as required in Section IV.F.2.a, Section IV.F.2.b, and Section IV.F.2.c
above will be provided using the CPS Energy Application for Pole Attachment Form,
provided in Appendix B and available at www.cpsenergy.com/poleattachments and
shall identify:
(i) Application Form specifying the Poles and Attachments subject to
Overlashing;
(ii) Total diameter and estimated weight of the existing Communications
Facilities subject to Overlash;
(iii)Diameter and estimated weight of the added Communications Facilities;
(iv) Owner of the Communication Facilities;
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(v) Total estimated diameter and weight of the Communications Facilities after
the Overlash;
(vi) Applicable PLA documents, if any; and
(vii) Applicable Make-Ready Electrical Construction engineering design
documents, if any.
3. CPS Energy Review of Application. All provisions of Section IV.B.3 shall be
applicable to Applications considered under the Competitive Provider – Standard Process
for Overlashing Existing Attachments, except as provided below:
a) Where no Make-Ready Electrical Construction is required, CPS Energy shall review
and provide written Notices to Proceed in accordance with the provisions of Section
IV.F.2.a and Section IV.F.2.b above.
b) Where Make-Ready Electrical Construction is required, the provisions of Section
IV.B.3 shall apply.
4. Make-Ready Electrical Construction. If required, all provisions of Section IV.B.4
shall be applicable to Make-Ready Work Electrical Construction for Applications
considered under the Competitive Provider – Standard Process for Overlashing Existing
Attachments.
5. Make-Ready Communication Construction – One Touch Transfers. If required, all
provisions of Section IV.B.5 shall be applicable to Make-Ready Communications
Construction for Applications considered under the Competitive Provider – Standard
Process for Overlashing Existing Attachments regarding One-Touch Transfers.
6. Make-Ready Communication Construction - Complex Transfers. If required all
provisions of Section IV.B.6 shall be applicable to Make-Ready Communications
Construction for Applications considered under the Competitive Provider – Standard
Process for Overlashing Existing Attachments regarding Complex Transfers.
7. Notice of Attachment Completion and Acceptance. All provisions of Section IV.B.7
shall be applicable to Notice of Attachment Completion and Acceptance for Applications
considered under the Competitive Provider – Standard Process for Overlashing Existing
Attachments.
8. Post Construction Inspection. All provisions of Section IV.B.8 shall be applicable to
Post Construction Inspection for Applications considered under the Competitive Provider
– Standard Process for Overlashing Existing Attachments.
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SECTION V.
SPECIFICATIONS FOR
WIRELESS INSTALLATIONS
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V. SPECIFICATIONS FOR WIRELESS INSTALLATIONS
A. Wireless Installation Application Process
CPS Energy offers Wireless Providers access to Poles and Overhead Streetlight Poles for the
purpose of attaching Wireless Installations pursuant to the Application processes outlined in
Figure E listed below. The technical specifications for Wireless Installations are found in
Appendix D, Appendix G, and Appendix I. Additional information, including the
Application Forms for a Wireless Installation, may be downloaded at
www.cpsenergy.com/poleattachments.
Figure E: Wireless Installation Application Process
Commented [A1]: Need to edit
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B. Standard Process for Wireless Installations
A high-level workflow of the Application review process, provided the Wireless Installations
(excluding Mid-Span Installations), provided the Wireless Installation system has completed
the Pre-Certified Equipment process pursuant to Section III.A.14, for the Standard Process
for Wireless Installations on CPS Energy Poles and Overhead Streetlight Pole illustrated in
Figure F below.on or supported by CPS Energy Poles and Overhead Streetlight Poles, is
illustrated in Figure F below.
1. Eligibility. Any Wireless Provider with a valid Wireless Installation Agreement or
combination of Pole Attachment Agreement and Wireless Addendum. A Wireless Provider
with a valid Wireless Installation Agreement or combination of Pole Attachment Agreement and
Wireless Addendum is eligible to elect to install Wireless Installations under this process.
2. Application for Permit Required. A Wireless Provider shall not install any new
Wireless Installation on any CPS Energy Pole or Overhead Streetlight Pole without first
submitting an Application and obtaining a Permit pursuant to the requirements and
procedures set forth below and elsewhere in these Standards.
a) Application Form. All Wireless Providers shall use the Application for Wireless
Installation form, provided in Appendix B and available for download at
www.cpsenergy.com/poleattachments, which may be amended from time to time,
provided that any such amendments are consistent with Applicable Engineering
Standards and are applied to similar types of Wireless Installations and similarly
situated Attaching Entities on a non-discriminatory basis.
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(i) A single Application may include up to a maximum of thirty (30) Wireless
Installation sites, together with the applicable Poles or Overhead Streetlight
Poles, provided that the Wireless Installation at each of the pole sites falls
within the identified boundaries of a Wireless Project Area and is consistent
with an approved Request for Pre-Certification Wireless System Form and
Wireless Equipment design configuration.
(ii) CPS Energy’s acceptance of the submitted design documents required as part
of a complete Application form (Section V.B.2.d) does not relieve the
Wireless Provider of full responsibility for any errors and/or omissions in the
engineering analysis and compliance with all Applicable Engineering
Standards.
b) Pole Ownership. For the purposes of Application submittal, unless CPS Energy
records and/or Poles indicate otherwise, CPS Energy shall be presumed to be the
owner all Poles subject to Attachment. The Wireless Provider is responsible for field
verifying Pole ownership and notifying CPS Energy of any discrepancies between
CPS Energy’s maps/records and the actual Poles in the field.
c) Compliance with Standards. Wireless Provider shall comply with the Texas
Engineering Act at Section 1001.001, et seq., of the Texas Occupations Code to the
extent it is applicable to the work described herein, and with the most current version
of the National Electrical Safety Code (NESC), including any and all revisions to
both, and all other Applicable Engineering Standards. The Wireless Provider shall
certify its compliance with the above on each Application it submits to CPS Energy
for processing. The certification statement shall be signed by an employee or agent
of the Wireless Provider who has the final authority or responsibility to approve the
Application. CPS Energy will not process an Application that fails to provide the
signed certification statement included therein. The Wireless Provider shall provide
documentation, sealed by an Engineer, establishing that the Wireless Provider’s
applicable Make Ready Electrical Construction design and Pole Loading Analysis
(PLA) documents comply with all requirements specified by the NESC and the
Applicable Engineering Standards.
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(i) Pole Loading Analysis (PLA). A Wireless Provider, in connection with an
Application, must comply with the PLA methodology described herein and in
Appendix G. Acceptable software for use of PLA shall be a commercially
available product with general industry acceptance. Should the Wireless Provider
utilize a commercially available software application that CPS Energy does not
possess; the Wireless Provider shall make available to CPS Energy at least one
software license for CPS Energy use at the Wireless Provider’s expense, subject
to CPS Energy’s Information Technology requirements. The Wireless Provider
will gather the physical and technical information for the requested Pole or
Overhead Streetlight Pole, Wireless Equipment, and wire Attachment associated
with the Wireless Installation required to conduct a PLA as described in Appendix
G, with assistance as required from CPS Energy.
d) Submission of Application. Completed Applications may be submitted by either U.S.
mail, electronically to [email protected], or other means mutually
agreeable by CPS Energy and the Wireless Provider. The Application shall include:
(i) Upon request, aA complete Application with all applicable supporting
documents, tests, reports, applications, permit numbers, and license
numbers;
(ii) Upon request, aA copy of an approved Request for Pre-Certification of
Wireless System form for the type of Wireless Installation proposed;
(iii)A copy of the Safety Briefing for the type of Wireless Installation proposed;
(iv) Engineering design documents created using the ANSI/SCTE Graphic
Symbols Drawing Standards, prepared or reviewed by an Engineer, and
including a detail description of the Wireless Installation in compliance
with all Applicable Engineering Standards, all detailed design documents
for any required Make-Ready Electrical Construction, and the Wireless
Provider’s estimated cost of any proposed Make-Ready Electrical
Construction;
(v) Upon request, tThe proposed deployment plan for the proposed Wireless
Project Area, including a description of how the Wireless Installation will
be served with electricity and backhaul broadband telecommunications
transport service;
(vi) A copy of an approved CPS Energy application for electric service showing
the electricity account number for the Wireless Installation, or a CPS
Energy letter identifying an existing electricity account number that will
service the Wireless Installation upon completion of construction;
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(vii) Report certifying compliance with FCC OET Bulletin 65 signage
requirements and the location of such signage on the Pole or Overhead
Streetlight Pole, if applicable;
(viii) PLA worksheets and results, as required by Appendix G;
(ix) Relevant Pole or Overhead Streetlight Pole identification data and
equipment tagging information; and
(x) If applicable, a Waiver Request form, as described in Section III.A.6.
Such Application shall be prepared by, or under the authority of, the Wireless
Provider. The detailed design documents” referenced in this Section V.B.2.d.iv will
be undertaken and completed in design tools to be determined by CPS Energy. All
actions pursuant to this Section V.B.2.d shall be at the Wireless Provider’s cost and
risk.
CPS Energy shall invoice the Wireless Provider the appropriate Application Fee
pursuant to Section II.I.2 and Appendix H.
3. CPS Energy Review of Application. CPS Energy will respond to each completed
Application and Make-Ready Engineering design documents submitted by the Wireless
Provider within thirty (30) calendar days of receipt. Should CPS Energy be required to
return an Application for clarification or modification, the time required for the Wireless
Provider to address the concerns raised and return the Application shall not count against
the thirty (30) calendar day period. An Application for a Mid-span Installation shall
highlight the path of the supporting Overlash back to the Slab-Mounted Equipment
Cabinet responsible for energizing the Mid-span Installation and identify the location of
such cabinet to ensure a Meter is installed at the cabinet. CPS Energy will process the
Overlash portion of the Application pursuant to Section IV.F. An Application for a DAS
System supporting wire Attachments that provide fiber backhaul transport service shall
similarly highlight the path back to a Slab-Mounted Equipment Cabinet or larger
enclosures located on private property and identify the Poles and/or Overhead Streetlight
Poles supported by such backhaul transport facilities that are part of the DAS system.
CPS Energy will process the backhaul transport Attachments that correspond with the
Application pursuant to Section IV.B. Any Application that does not conform to the
requirements provided in Section V.B.2.d and the Applicable Engineering Standards will
be deemed incomplete and immediately rejected by CPS Energy. If an Application is
rejected as incomplete, the Wireless Provider will be provided with a detailed description
of changes, modifications, or revisions to the Application necessary for CPS Energy’s
review and approval within ten (10) calendar days of receipt of the Application.
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In the event CPS Energy does not finalize its review of a complete Application within
thirty (30) calendar days, CPS Energy may impose a one-time, additional ten (10)
calendar day extension period in which to complete its review for each Application. CPS
Energy shall provide the Wireless Provider with seven (7) calendar days’ prior notice
that it intends to exercise its option to impose the extension period. A Wireless
Installation shall never be installed without the affirmative written consent of CPS
Energy and issuance of a Permit.
a) Review. In making its decision as to whether to issue a Permit, CPS Energy will
consider engineering and safety requirements, in accordance with the Applicable
Engineering Standards set forth in Section II.A.4. In addition, CPS Energy shall
consider Capacity constraints, including the future needs of CPS Energy as
determined in accordance with the Reserved Capacity provisions set forth in Section
II.H.10, flood zone requirements, in-flight CPS Energy projects, and other
circumstances known at the time that would directly affect the engineering, safety
requirements, and Capacity constraints associated with desired Poles or Overhead
Streetlight Poles. Specifically, CPS Energy will not consider a pole-mounted
Wireless Installation on a pole that is subject to a pending Wireless Installation
Application or which is already hosting a Wireless Installation. Other Capacity
constraints may impact approval of a Wireless Installation Application as described
in Section V.B.3.f below.
b) Make-Ready Electrical Construction. In the event that a Wireless Provider’s
proposed Application requires CPS Energy to undertake and complete Make-Ready
Electrical Construction to accommodate the Wireless Provider’s request, CPS Energy
will review the detailed design documents and the cost estimate for this Make-Ready
Electrical Construction work provided by the Wireless Provider. Following CPS
Energy’s approval of the Make-Ready Electrical Construction design and review of
the estimated Make-Ready Electrical Construction costs, CPS Energy may, at its
discretion, revise the cost estimate to more accurately reflect the anticipated cost of
the work. CPS Energy will then submit this estimate of the cost of Make-Ready
Electrical Construction to the Wireless Provider utilizing the CPS Energy
Authorization for Make-Ready Work form, provided in Appendix B, for approval
from the Wireless Provider to proceed. The Wireless Provider shall approve the
make advanced payment of this cost estimate in order for any Make-Ready Electrical
Construction to procced in accordance with the provisions of Section II.I.3. The
Wireless Provider shall have fifteen (15) calendar days following the issuance of the
CPS Energy Authorization for Make-Ready Work invoice to approve the estimate
and provide payment. Failure of the Wireless Provider to respond to CPS Energy or
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return the CPS Energy Authorization for Make-Ready Work invoice within the
fifteen (15) calendar day period will result in the Application being cancelled by CPS
Energy, with all applicable Application Fees being non-refundable.
c) Changes Required. If CPS Energy describes any changes, modifications, or revisions
to the proposed Make-Ready Electrical Construction design documents pursuant to
this Section V.B.3, CPS Energy shall notify the Wireless Provider in writing. Upon
receipt of such notice, the Wireless Provider may notify CPS Energy in writing that
it agrees to the changes, modifications, or revisions to the proposed Make-Ready
Electrical Construction required by CPS Energy, in which case the Wireless Provider
may resubmit the Application as amended and it shall be deemed granted; or the
Wireless Provider may propose alternative changes, modifications, or revisions
consistent with Applicable Engineering Standards by resubmitting the Application
with such other alternative proposals, provided that such resubmission explains the
reasons for the alternative proposals and addresses all concerns raised by CPS Energy
in response to the initial Application. The alternative proposals shall not be the
original Make-Ready Engineering design documents rejected by CPS Energy.
The Wireless Provider shall incur an Application Fee upon resubmitting the
Application containing the alternative proposals. CPS Energy shall have thirty (30)
calendar days of receipt thereof to provide the Wireless Provider with:
(i) Notification that access is granted based on the alternative proposals; or
(ii) A detailed description of any changes, modifications, or revisions to the
alternative proposal necessary to comply with safety, reliability, or generally
applicable engineering practices or standards.
In the event CPS Energy fails to complete its review within thirty (30) calendar
days of the resubmitted Application containing the alternative proposals for
Make-Ready Electrical Construction, CPS Energy may impose an additional ten
(10) calendar day extension period in which to complete its review of the
resubmitted Application. CPS Energy shall provide the Wireless Provider with
seven (7) calendar days’ prior notice that it intends to exercise its option to impose
the extension period. A Wireless Installation shall never be installed without the
affirmative written consent of CPS Energy and the issuance of a Permit.
d) Compliance by Wireless Provider. CPS Energy’s acceptance of the submitted Make-
Ready Electrical Construction design and engineering documents does not relieve the
Wireless Provider from compliance with the requirements of the Texas Engineering
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Act, the National Electrical Safety Code, and all other Applicable Engineering
Standards as required by this Standard.
e) Application Approval.
(i) If Make-Ready Electrical Construction Is Required. After acceptance of all
necessary revisions, CPS Energy will issue to the Wireless Provider the CPS
Energy Authorization for Make-Ready Work, a copy of which is in Appendix B.
The Wireless Provider shall comply with the provisions of Section V.B.4.
(ii) If Make-Ready Electrical Construction Is Not Required. After acceptance of all
necessary revisions to the Application, CPS Energy will issue to the Wireless
Provider the CPS Energy Notice to Proceed, a copy of which is in Appendix B.
The Wireless Provider shall comply with the provisions of Section V.B.4.e.
f) Treatment of Multiple Requests for Poles in the Same General Area. CPS Energy
will not authorize more than one Wireless Installation per Pole or Overhead
Streetlight Pole. Pole assignments for Wireless Installation Applications shall be
considered on a “first-come, first-served”, non-discriminatory basis. Should a
Wireless Provider fail to install a Wireless Installation within the allotted time frame,
the requested Pole or Overhead Streetlight Pole will be released and made available
to another Wireless Provider upon request as further described in Section V.B.3.fg.ii
below. Multiple requests to install Wireless Installations in the same general area
will be treated as described Section V.B.3.fg.ii below. The treatment of Mid-span
Installations and DAS System Antenna node installations in potential conflict with
other Wireless Installations is described in Section V.B.3.fg.iii and Section
V.B.3.g.iv. Requests for pole assignments as part of a neutral host DAS System shall
not be considered as multiple requests for the same poles, provided however that such
requests will only be considered when the Infrastructure Provider has obtained
contractual commitments from multiple CMRS Providers to jointly occupy the DAS
System.
(i) If CPS Energy issues a Permit and the Wireless Provider fails to install the
Wireless Installation in compliance with Section V.B.4.f, CPS Energy will make
available the requested Pole or Overhead Streetlight Pole to another Wireless
Provider that may have expressed an interest in the affected pole.
(ii) In situations where CPS Energy receives multiple Wireless Installation
Applications for Poles within the same general area from different Wireless
Providers, CPS Energy will limit a Wireless Provider to only one Wireless
Installation for every six (6) contiguous Poles and/or Overhead Streetlight Poles.
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Under no circumstances, will a Wireless Provider be allowed to reserve a Pole or
Overhead Streetlight Pole for future use.
(iii)Regarding Applications for Mid-span Installations, CPS Energy will not allow
more than one (1) such installation between any two (2) contiguous distribution
Poles. Mid-span Installations shall not be installed on any Attachments
suspended from Overhead Streetlight Poles. A pole-mounted Wireless
Installation may not be installed on a Pole that hosts an Attachment that supports
a Mid-span Installation.
(iv)(iii) Regarding a DAS System, an Antenna node shall not be attached on a Pole
that already hosts a pole-mounted Wireless Installation and vise-versa. A Mid-
span Installation may not be clamped onto an Attachment that is installed on a
Pole that hosts a DAS System Antenna node.
4. Make-Ready Electrical Construction. If Make-Ready Electrical Construction is
required to accommodate a Wireless Installation, CPS Energy or its contractors shall
perform such work at Wireless Provider’s expense as provided in Section V.B.3, Section
V.B.5.e, and Appendix B.
a) Advance Payment. Upon execution of CPS Energy Authorization for Make-Ready
Work by a Wireless Provider, CPS Energy shall schedule the Make-Ready Electrical
Construction. Pursuant to Sections II.I.3, CPS Energy shall require payment in
advance for any Make-Ready Electrical Construction to be performed by CPS Energy
or its contractors based upon the estimated cost of such work.
b) Work Performed by CPS Energy or CPS Energy Contractor. Make-Ready Electrical
Construction shall be performed only by CPS Energy and/or a contractor authorized
by CPS Energy to perform such work. Prior to commencement of Make-Ready
Electrical Construction and upon receipt of advance payment, CPS Energy will
schedule a work order within thirty (30) calendar days. CPS Energy will strive to
perform the Make-Ready Electrical Construction to accommodate an Attaching
Entity’s Communications Facilities within sixty (60) calendar days. CPS Energy
shall provide to the Wireless Provider as soon as possible the estimated schedule for
completing the Make-Ready Electrical Construction. In the event that CPS Energy
is unable to complete the Make-Ready Electrical Construction within the sixty (60)
calendar day period, a Wireless Provider may request in writing to CPS Energy the
use of temporary Wireless Installation by submitting a Request for Temporary
Attachment form, a copy of which is available at
www.cpsenergy.com/poleattachments and located in Appendix B. Upon receiving
this written request, CPS Energy shall coordinate with the Wireless Provider on a
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non-discriminatory basis to determine all reasonable means to accommodate the
temporary Wireless Installation request subject to compliance with the Applicable
Engineering Standards.12 Any temporary Wireless Installations must be removed and
properly installed upon the completion of the Make-Ready Electrical Construction.
The cost to install and remove a temporary Wireless Installation shall be borne by the
Wireless Provider.
c) Work Schedule. In performing all Make-Ready Electrical Construction to
accommodate a Wireless Provider’s Wireless Installations, CPS Energy will include
such work in its normal work schedule on a non-discriminatory basis. In the event
the Wireless Provider requests that the Make-Ready Electrical Construction be
performed on a priority basis or outside of CPS Energy’s normal work hours, the
Wireless Provider shall pay the appropriate increased costs. Nothing herein shall be
construed to require performance of any Wireless Provider’s work before other
scheduled work, CPS Energy service restoration, or other Emergency work.
d) Notifying Other Attaching Entities. Prior to commencing Make-Ready Electrical
Construction, CPS Energy shall provide no less than ten (10) calendar days’ written
notice to the Wireless Providers, if any, on the affected pole structure of the impending
work. Such written notice shall be provided through NJUNS.
e) Notice to Proceed. Following completion of the Make-Ready Electrical
Construction, CPS Energy will issue a CPS Energy Notice to Proceed, a form of
which is provided in Appendix B, to the Wireless Provider (applicant) in writing that
the Pole or Overhead Streetlight Pole is available for Make-Ready Wireless
Installation Construction. When applicable, the Wireless Provider shall proceed to
install its Wireless Installations utilizing the One-Touch Transfer Process described
in Section V.B.5 below. Whenever the transfer of an Attachment would require the
cutting or splicing of the Communication Facility, the Complex Transfer Process in
Section V.B.6 below shall apply.
f) Failure to Attach. A Wireless Provider must exercise the right granted by the CPS
Energy Notice to Proceed within ninety (90) calendar days of issuance of the Notice
to Proceed. If needed, the Wireless Provider may request in writing to CPS Energy
an additional thirty (30) calendar day extension of the effective period of the Notice
to Proceed. The request for this extension must be received by CPS Energy no later
than seven (7) calendar days before the expiration date provided in the Notice to
Proceed. In considering this request, CPS Energy will review past construction
12 NESC, Rule 013B4 and Rule 014, C2-2017.
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practices of the Wireless Provider and current efforts underway to complete the
installation for which the extension was requested. CPS Energy will provide a written
response to the request for extension within three (3) calendar days of receiving the
request. CPS Energy, at its discretion, may not consider any requests for extension
received within seven (7) calendar days of the expiration of the Notice to Proceed.
(i) Failure to install a Wireless Installation within the effective period of the Notice
to Proceed, or extended period if granted by CPS Energy, will result in expiration
of the Application and the forfeiture of the applicable Application Fees and any
payments made for Make-Ready Work already completed. Following expiration
of an Application, should the Wireless Provider wish to continue to install the
Wireless Installation subject to the expired Application, the Wireless Provider
must submit a new Application covering the same Wireless Installation including
all appropriate Application Fees.
(ii) CPS Energy and the Wireless Provider shall determine a mutually-agreeable
schedule for the completion of the Make-Ready Work should an issue of Force
Majeure, as described in the Wireless Installation Agreement, be asserted by
either party.
5. Make-Ready Wireless Installation Construction – One Touch Transfer. The transfer
of third-party Attachments, whether conducted by a Wireless Provider or CPS Energy,
in order to accommodate a Wireless Installation shall be part of the One-Touch Transfer
Process as further described herein. Pursuant to these Standards, under the One-Touch
Transfer Process, a Wireless Provider permitted to make a Wireless Installation may
transfer or rearrange the Attachments of one or more Attaching Entities in the
Communications Space of a distribution Pole as may be necessary to accommodate the
new Wireless Installation contingent upon compliance with requirements identified in
this Section V.B.5. All One-Touch Transfers conducted by a Wireless Provider or CPS
Energy must comply with the following requirements:
a) Simple Transfers Only. One-Touch Transfers shall be limited to the rearrangement
or transfer of a third-party Attachment on an existing Pole and Mid-Span Installation
suspended by a Messenger cable between two Poles. Such Attachment or Mid-span
Installation may be rearranged within an existing Pole or transferred onto a
replacement Pole, provided the affected Attachment or Mid-span Installation (along
with any supporting Communication Facility or Overlash) is not subject to cutting
and splicing and any affected Mid-span Installation is not severed from the
Communication Facility providing connectivity.
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b) Certified Contractors. A Wireless Provider must engage qualified contractors
approved by CPS Energy pursuant to a certification program developed by CPS
Energy with the input of Wireless Providers.
c) Applicability to CPS Energy. CPS Energy’s communications wires or facilities
installed in the Communication Space of a Pole will also be subject to the One-Touch
Transfer Process.
d) One-Touch Transfers Subject to Applicable Engineering Standards. All Make-Ready
Wireless Installation Construction performed under the One-Touch Transfer Process
shall meet all Applicable Engineering Standards, including CPS Energy’s clearance
standards. As part of the Make-Ready Wireless Installation Construction, a Wireless
Provider may modify one or more Attachments on a Pole and any Mid-span
Installation suspended from a Messenger cable between two Poles, by relocating said
Attachments/Messengers within an existing Pole or transferring the
Attachments/Messengers onto a replacement Pole, as necessary to accommodate the
Wireless Installation. Applications that include Make-Ready Wireless Installation
Construction and One-Touch Transfers that fail to meet Applicable Engineering
Standards will be rejected by CPS Energy.
e) Cost Responsibility. With the exception of instances where in the sole judgement of
CPS Energy a Pole is identified as defective, in which case CPS Energy will be
responsible for the cost to replace such defective Pole, the Wireless Provider shall
pay all costs of Make-Ready Wireless Installation Construction associated with One-
Touch Transfers as described below:
(i) Where the Pole includes one or more third-party Attachment(s) that fail to meet
Applicable Engineering Standards but otherwise there is enough space on the
Pole to accommodate the Wireless Provider’s Wireless Installation, Make-Ready
Work will not include the transfer of the third-party Attachment(s), unless the
lowest Attachment on the Pole fails to meet NESC clearance standards and/or
poses a public safety hazard. In this specific case, the Wireless Provider shall
notify CPS Energy, who will notify the owner of the non-compliant Attachment
that the Attachment is non-compliant with the Applicable Engineering Standards
or presents a Safety Violation in accordance with the provisions of Section II.K.3.
The Wireless Provider requesting the Wireless Installation will not be allowed to
undertake the installation of the Wireless Installation until the non-compliant
Attachment is remedied.
(ii) Where the Pole includes one or more third-party Attachment(s) that fail to meet
Applicable Engineering Standards, and in order to accommodate the Wireless
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Provider’s Wireless Installation on the same Pole the third-party Attachment(s)
must be rearranged, the cost of rearranging the third-party Attachment(s) will be
included in Make Ready Work. Provided that if the lowest Attachment on the
Pole fails to meet NESC clearance standards and/or poses a public safety hazard,
the Wireless Provider may recover the cost to bring such Attachment into
compliance from the owner of that Attachment, but no others.
(iii)Where the Pole includes one or more third-Party Attachment(s) that fail to meet
Applicable Engineering Standards, and in order to accommodate the Wireless
Provider’s Wireless Installation a new Pole must be installed, the cost of the new
Pole and the transfer of the third-party Attachment(s) will be included in the
Make-Ready Work.
(iv) Where the Pole includes one or more third-party Attachment(s) that meet
Applicable Engineering Standards, and otherwise there is enough space on the
Pole to accommodate the Wireless Provider’s Wireless Installation, Make-Ready
Work will not include the transfer of the third-party Attachment(s).
(v) Where the Pole includes one or more third-party Attachment(s) that comply with
Applicable Engineering Standards, and in order to accommodate the Wireless
Provider’s Wireless Installation on the same Pole the third-party Attachment(s)
must be rearranged, the cost of rearranging the third-party Attachment(s) will be
included in Make-Ready Work.
(vi) Where the Pole includes one or more third-party Attachment(s) that comply with
Applicable Engineering Standards, and in order to accommodate the Wireless
Provider’s Wireless Installation a new Pole must be installed, the cost of the new
Pole and the transfer of the third-party Attachment(s) will be included in Make-
Ready Work.
f) Notice of Transfer. A Wireless Provider shall provide all third-parties affected by a
proposed One-Touch Transfer with advance written notice of such One-Touch
Transfer no less than twenty-one (21) calendar days prior to undertaking such One-
Touch Transfer. This notice shall be provided using NJUNS to a duly designated
representative of the affected Attaching Entity, unless another method of notice is
prescribed by CPS Energy. Such notice shall identify the specific Pole subject to the
Wireless Installation and affected by such One-Touch Transfer. The Wireless
Provider that desires to utilize the One-Touch Transfer Process shall bear the
responsibility of determining the appropriate representative for each Attaching Entity
affected by the Wireless Provider’s implementation of the One-Touch Transfer
Process.
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g) Critical Communication Facilities. If an affected Attaching Entity, in its reasonable
discretion, determines that a proposed One-Touch Simple Transfer poses a risk of
disconnection or interruption of service to a Critical Communications Facility, the
affected Attaching Entity shall notify the requesting Wireless Provider and CPS
Energy in writing within ten (10) calendar days of receiving the notice of transfer
described in Section V.5.f. The affected Attaching Entity is obligated to make the
requested transfer of its Critical Communication Facilities within fifteen (15)
calendar days of providing such notice. Failure to transfer the Critical
Communications Facilities in a timely manner will subject the Critical
Communications Facilities to the One-Touch Transfer Process.
h) Post-Transfer Notice. Within fifteen (15) calendar days following the completion of
a One-Touch Transfer, the Wireless Provider shall send written notice of the One-
Touch Transfer and as-built reports to each affected Attaching Entity. Within thirty
(30) calendar days of receipt of these as-built reports, the Attaching Entity that owns
the Communications Facilities that were transferred or relocated may conduct an
inspection at the expense of the Wireless Provider who moved the facilities. If the
One-Touch Transfer failed to meet all Applicable Engineering Standards, the owner
of the Communications Facilities subject to transfer or relocation will notify the
Wireless Provider responsible for the One-Touch Transfer of any deficiency, which
will be corrected within fifteen (15) calendar days following receipt of such written
notice at the expense of the Wireless Provider responsible for the One-Touch
Transfer. The Wireless Provider responsible for the One-Touch Transfer shall pay
the actual, reasonable, and documented inspection expenses incurred by the owner of
the Communication Facilities subject to transfer or relocated, within forty-five (45)
calendar days of receipt of an invoice. Failure of the owner of the relocated
Attachment to undertake and complete the inspection with the thirty (30) calendar
day period shall be deemed acceptance of the One-Touch Transfer.
i) Attaching Entity’s Attachments Subject to One-Touch Transfer by Wireless
Providers. An Attaching Entity’s Communications Facilities shall be subject to the
One-Touch Transfer Process conducted by a Wireless Provider or CPS Energy
pursuant to the same terms and conditions prescribed in this Section V.B.5 and in
Appendix H.
6. Make-Ready Wireless Installation Construction - Complex Transfers.
a) Responsibility for Complex Transfers. The accomplishment of a Complex Transfer
is considered part of Make-Ready Wireless Installation Construction and shall be
performed by the Attaching Entity which owns the Attachment subject to transfer. It
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is the responsibility of the Wireless Provider requesting the Complex Transfer to
negotiate a private process with the affected Attaching Entity to accomplish the
Complex Transfer. The cost of the Complex Transfer shall be borne by the requesting
Wireless Provider.
b) Complex Transfers Escalation Process. In the event a Wireless Provider refuses to
reach agreement on a process for the expedient transfer of an Attachment or Wireless
Installation subject to a Complex Transfer, the requesting Wireless Provider may rely
on the following escalation procedures. At any time during these escalation
procedures, the requesting Wireless Provider and the owner of the Attachment or
Wireless Installation subject to the Complex Transfer may reach agreement on a
voluntary transfer process. In such event, the requesting Wireless Provider shall
notify CPS Energy in writing of this agreement.
(i) Level 1: Initial Request for Complex Transfer (Days 0 to 30)
a. Initial Notice Letter. The requesting Wireless Provider shall provide written
notice to owner of the Attachment or Wireless Installation subject to Complex
Transfer requesting the transfer of such Attachment using NJUNS with a copy
to CPS Energy. The Attaching Entity which owns such Attachment or
Wireless Installation shall perform the transfer within thirty (30) calendar
days of receipt of notice from the requesting Wireless Provider.
(ii) Level 2: Initial Escalation Process (Days 31 to 60)
a. Escalation Notification. If the owner fails to transfer the Attachment or
Wireless Installation subject to Complex Transfer within the initial thirty (30)
calendar days, the requesting Wireless Provider shall send a certified letter
notifying the non-compliant Attaching Entity that failure to transfer the
Attachment or Wireless Installation within a subsequent thirty (30) calendar
days (escalation period) of receipt of notice will result in the Attachment or
Wireless Installation in question being designated by CPS Energy as non-
compliant with the Complex Transfer Process and subject to penalty, as
described in Appendix H, on the basis of interference with the requesting
Wireless Provider’s permitted Attachment rights. The requesting Wireless
Provider shall send CPS Energy a copy of the escalation letter and all other
correspondence between the parties related to this matter.
b. Duty to Negotiate. The requesting Wireless Provider is required to continue
negotiations with the non-compliant Attaching Entity during the thirty (30)
calendar day escalation period. Absent extraordinary circumstances, the non-
compliant Attaching Entity’s failure to transfer the Attachment or Wireless
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Installation subject to Complex Transfer by the end of the thirty (30) calendar
day escalation period shall be considered a lack of cooperation on the part of
the non-compliant Attaching Entity. Conversely, absent extraordinary
circumstances, a refusal by the requesting Wireless Provider to agree to an
alternative process for the transfer of the Attachment or Wireless Installation
in question within a reasonable date certain shall be considered a lack of
cooperation on the part of the requesting Wireless Provider.
c. Notice of Success Complex Transfer. If the non-compliant Attaching Entity
transfers the Attachment or Wireless Installation subject to Complex Transfer
within the thirty (30) calendar day escalation period, or the requesting
Wireless Provider transfers the Attachment or Wireless Installation by mutual
agreement of the parties, no further escalation will be necessary.
(iii) Level 3: CPS Energy Finding of Non-Compliant Attachments (Days 61 to 90)
a. Request for Finding of Non-compliant Attachments or Wireless
Installations. If the requesting Wireless Provider and the non-compliant
Attaching Entity cannot reach agreement and the non-compliant Attaching
Entity fails to transfer the Attachment or Wireless Installation subject to
Complex Transfer within the thirty (30) calendar day escalation period; the
requesting Wireless Provider within five (5) calendar days thereafter shall
notify CPS Energy in writing, provide a short summary of efforts to negotiate
the rearrangement or transfer of the Attachment or Wireless Installation in
question, and request CPS Energy to make a finding of Non-complaint
Attachment or Wireless Installation on the basis of interference with the
requesting Wireless Provider’s permitted attachment rights. The request shall
explain why the requesting Wireless Provider believes the non-compliant
Attaching Entity is acting in bad faith.
b. Notification of Non-Compliant Attachments. Within ten (10) calendar days
of receiving the request for a finding of non-compliant Attachment or
Wireless Installation, CPS Energy will evaluate the request and if it finds the
request credible; CPS Energy will:
(1) Notify the non-compliant Attaching Entity by certified mail that CPS
Energy has determined the Attachment or Wireless Installation subject to
Complex Transfer is declared as either a “Non-compliant Attachment” or
“Non-compliant Wireless Installation,” as appropriate;
(2) The non-conforming Attaching Entity will begin accruing penalties as
provided in Appendix H of these Standards until the Non-compliant
Attachment or Non-compliant Wireless Installation is transferred; and
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(3) CPS Energy will suspend the processing of the non-compliant Attaching
Entity’s Applications effective five (5) days after receipt of the certified
letter.
Thereafter, the non-compliant Attaching Entity will have fifteen (15) calendar
days in which to transfer the non-compliant Attachment or non-compliant
Wireless Installation and notify CPS Energy in writing in order to reinstate
the processing of Applications. If the non-compliant Attaching Entity fails to
transfer the non-compliant Attachment or non-compliant Wireless Installation
within the twenty (20) calendar day grace period, the non-compliant
Attachment or non-compliant Wireless Installation will be subject to further
penalties and transfer as provided in Section III.E and Appendix H. CPS
Energy will reinstate the processing of the non-compliant Attaching Entity’s
Applications upon receipt of written notification of the transfer of the non-
compliant Attachment or non-compliant Wireless Installation and the
payment of all assessed penalties.
c. Duty to Negotiate. The requesting Wireless Provider is required to continue
negotiations with the non-compliant Attaching Entity which owns the non-
compliant Attachment or Wireless Installation during the twenty (20)
calendar day grace period.
d. Notice of Transfer. If the non-compliant Attaching Entity transfers the non-
compliant Attachment or non-compliant Wireless Installation within the
twenty (20) calendar day grace period, or the requesting Wireless Provider
transfers the non-compliant Attachment or non-compliant Wireless
Installation by mutual agreement of the parties, the moving party shall notify
CPS Energy by electronic message, CPS Energy shall reinstate processing of
the non-compliant Attaching Entity’s Applications within twenty-four (24)
hours of receiving payment of all outstanding penalties.
e. Stop Processing Applications. If CPS Energy does not receive written
notification of the transfer of the non-compliant Attachment or non-compliant
Wireless Installation by the end of the twenty (20) calendar day grace period,
CPS Energy shall stop processing the non-compliant Attaching Entity’s
Applications pending further written notice of a successful transfer and the
payment of all outstanding penalties.
(iv) Level 4: Transfer or Removal of Unauthorized Attachments (Days 91 and
Beyond)
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a. Notification of Failed Transfer. If the parties fail to negotiate the successful
transfer of the non-compliant Attachment or non-compliant Wireless
Installation, the requesting Wireless Provider shall promptly notify CPS
Energy in writing of the failed attempt and explain the reasons for the
unsuccessful transfer.
b. Notification of Transfer of Non-compliant Attachments. Following receipt of
the notification of failed transfer, CPS Energy shall promptly proceed to
transfer the non-compliant Attachment or non-compliant Wireless
Attachment at the respective owner’s expense. Following the transfer of the
non-compliant Attachment or non-compliant Wireless Attachment, CPS
Energy will provide written notification of the transfer to the non-compliant
Attaching Entity within twenty-four (24) hours. CPS Energy shall reinstate
processing of the non-compliant Attaching Entity’s Applications within
twenty-four (24) hours of receiving payment for the transfer cost and all
outstanding penalties.
c. Notice of Transfer. In the event the non-compliant Attaching Entity transfers
the non-compliant Attachment or non-compliant Wireless Installation, or the
requesting Wireless Provider transfers the non-compliant Attachment or non-
compliant Wireless Installation by mutual agreement of the parties, prior to
CPS Energy’s transfer efforts, the moving party shall notify CPS Energy in
writing. The non-compliant Attaching Entity shall be assessed a one-time
fine as provided in Appendix H of these Standards. Thereafter, CPS Energy
shall reinstate the processing of the non-compliant Attaching Entity’s
Applications within twenty-four (24) hours of receiving payment of all
outstanding penalties.
7. Notice of Attachment Completion and Acceptance.
The Attaching Entity shall notify CPS Energy in writing by submitting the Completion
of Attaching Entity Construction form, a copy of which is available at
www.cpsenergy.com/poleattachments and in Appendix B, within ten (10) calendar days
following the acceptance by all Attaching Entities whose facilities were rearranged or
transferred pursuant to Section V.B.5 (Simple Transfer) and/or Section V.B.6 (Complex
Transfers) that all Make-Ready Wireless Installation Construction has been completed
and accepted, and that the new Wireless Installation and all Make-Ready Work are ready
for CPS Energy to undertake Post-Construction Inspection.
8. Post-Construction Inspection.
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a) Construction Subject to Inspection. CPS Energy shall complete a Post-Construction
Inspection of applicable Make-Ready Work at the Wireless Provider’s expense
within thirty (30) calendar days of receiving the Attaching Entity’s notification set
forth in Section V.B.7. CPS Energy will conduct the Post-Construction Inspections
to evaluate compliance with the requested Permit, Applicable Engineering Standards,
or other design and installation requirements. Completion of a Post-Construction
Inspection by CPS Energy shall not in any way relieve any Wireless Provider or the
Wireless Provider’s insurers of any responsibility, duty, obligation, or liability under
these Standards, any contractual agreement, or otherwise; nor does CPS Energy’s
ability to make Post-Construction Inspections relieve a Wireless Provider from its
obligations to exercise due care in the installation of its Wireless Installations. The
Post-Construction Inspection provision set forth in this Section V.B.8.a does not
affect any other inspection requirements elsewhere in these Standards. This section
V.B.8 also applies to supplemental Post-Construction Inspections where the
Attaching Entity reports “final corrections” of previously identified non-compliant
work or locations as described in Section V.B.8.b below.
b) Compliance. In the event a Post-Construction Inspection conducted pursuant to
Section V.B.8.a reveals that corrections or other actions are required of a Wireless
Provider, including without limitation those required for reasons of safety or
structural integrity, the Wireless Provider shall make such required corrections or
take the requested actions within thirty (30) calendar days after the date CPS Energy
sends written notice. If CPS Energy determines in its reasonable judgment and
discretion that the needed corrections rise to the level of an Emergency, CPS Energy
may perform the necessary corrective work without providing notice, at the Wireless
Provider’s sole risk and cost plus ten-percent (10%). As soon as practicable
thereafter, CPS Energy will advise the Wireless Provider of the work performed or
the action taken.
c) Issuance of Permit. Upon satisfactory completion of the Post-Construction
Inspection, CPS Energy shall notify the Wireless Provider in writing that CPS Energy
has approved the Wireless Installation identified in the Application by submitting to
the Wireless Provider a Permit, a copy of which form is located in Appendix B, for
said applicable Wireless Installation.
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C. Standard Process for Strand-Mounted Mid-Span Installations.
1. Eligibility. An Attaching Entity seeking only the deployment of Mid-Span Installations
is eligible to make such installations, provided that it (a) has executed a Pole Attachment
Agreement; and (b) follows the requirements of this Section V.C.
2. Advance Notice of Mid-Span Installations Required. All provisions of Section V.B.2
shall be applicable to Notifications considered under the Section V.C. applicable to
strand-mounted Mid-Span Installations, except as provided below:
a) For Mid-Span Installations, an Attaching Entity shall provide CPS Energy with a
Notification conforming to the requirements of subsection (b) of this section, rather
than an Application, not less than ten (10) calendar days before the proposed date of
installation.
b) An Attaching Entity shall provide such notice as is required herein using the
applicable Notification listed in the CPS Energy Pole Attachment Services Forms,
provided in Appendix B and available at www.cpsenergy.com/poleattachments and
shall identify, provide, or demonstrate:
(i) The Poles and Messenger cable intended to support the proposed Mid-Span
Installation;
(ii) The total diameter and estimated weight of the existing Messenger cable and
Overlashed Communications Facility intended to support the proposed Mid-
Span Installation;
(iii) The dimensions and estimated weight of the proposed Mid-Span Installation;
(iv) The owner of the Messenger cable;
(v) The total weight of the Messenger cable supporting the proposed Mid-Span
Installation and the Overlashed Communications Facility providing
connectivity and energizing the proposed Mid-Span Installation;
(vi) The path from the Mid-Span Installation to the Slab-Mounted Equipment
Cabinet providing the power source energizing such installation;
(vii) Applicable Make-Ready Work engineering design documents, if any; and
(viii) That the proposed Mid-Span Installation meets all Applicable Engineering
Standards.
c) A Mid-Span Installation and associated equipment attached to or supported by a
Messenger cable shall not exceed 25 pounds.
3. CPS Energy Review of Notification; Construction; Permitting.
a) Identification of Capacity, Safety, Reliability, or Engineering Issue. If, after CPS
Energy receives a Notification of Mid-Span Installation, CPS Energy determines that
the proposed Mid-Span Installation would create one or more capacity, safety,
reliability, or engineering issues requiring correction, CPS Energy shall provide
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specific documentation of the issue or issues to the Attaching Entity seeking the Mid-
Span Installation within the ten (10) calendar day notice period. CPS Energy will not
charge a fee to the Attaching Entity seeking a Mid-Span Installation in connection
with the submission, review, or processing of the Attaching Entity’s Notification of
Mid-Span Installation.
b) Attaching Entity Actions in Response to Identification of Issue Requiring Correction;
CPS Energy Response. Upon receipt of CPS Energy’s documentation of one or more
capacity, safety, reliability, or engineering issues requiring correction in a proposed
Mid-Span Installation, the Attaching Entity shall modify the proposed Mid-Span
Installation to address the issue or issues CPS Energy has identified and shall provide
CPS Energy with notice of the proposed means of correction through an amended
Notification of Mid-Span Installation.
c) Processing of Amended Notification of Mid-Span Installation. If the Attaching
Entity submits an amended Notification of Mid-Span Installation, CPS Energy shall
have five (5) business days in which to review the amended Notification of Mid-Span
Installation to determine if the proposed Mid-Span Installation would create one or
more capacity, safety, reliability, or engineering issues requiring correction, and if
so, to provide the Attaching Entity with specific documentation of the issue or issues.
The Attaching Entity must address the issue or issues CPS Energy has identified and
shall provide CPS Energy with notice of the proposed means of correction through
an amended Notification of Mid-Span Installation.
c) Construction and Notice of Completion. If within the ten (10) calendar day
Notification of Mid-Span Installation notice period or any five (5) business day
amended Notification of Mid-Span Installation notice period (i) CPS Energy does not
identify any capacity, safety, reliability, or engineering issue in the proposed Mid-
Span Installation requiring correction; or (ii) the Attaching Entity submits an
amended Notification of Mid-Span Installation curing the issue or issues CPS Energy
has identified, the Attaching Entity may proceed with construction of the proposed
Mid-Span Installation in accordance with (x) the terms of the original or amended
Notification of Mid-Span Installation in response to which CPS Energy has not
identified any capacity, safety, reliability, or engineering issue; and (y) including any
requirements pertaining to Make-Ready Work as provided in Sections V.C. 4., 5., 6.,
and 7. When construction of the Mid-Span Installation is complete, the Attaching
Entity shall within ten (10) business days provide CPS Energy with a Notice of
Completion pursuant to Section V.C.8. hereof.
d) Post-Construction Inspection and Permit Issuance. Upon receipt of the Attaching
Entity’s Notice of Completion, CPS Energy shall perform a Post-Construction
Inspection of the completed Mid-Span Installation in accordance with Section V.C.9.
hereof to identify any capacity, safety, reliability, or engineering issue the completed
construction of the Mid-Span Installation presents. If the completed Mid-Span
Installation presents any capacity, safety, reliability, or engineering issues, CPS
Energy shall notify the Attaching Entity, and the Attaching Entity shall within ten
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(10) business days take such actions as are necessary to cure the issue or issues
identified. If upon completion of the Post-Construction Inspection CPS Energy does
not identify any capacity, safety, reliability, or engineering issue in the completed
Mid-Span Installation requiring correction, or the Attaching Entity cures the issue or
issues CPS Energy has identified in the Post-Construction Inspection, CPS Energy
shall issue a Permit in accordance with the terms of the original or amended
Notification of Mid-Span Installation and conforming to any correcting construction,
as appropriate.
4. No Make-Ready Communications or Make-Ready Electrical Construction. Where
no Make-Ready Communications or Make-Ready Electrical Construction is required and
the proposed Mid-Span Installation otherwise conforms to all Applicable Engineering
Standards, the Attaching Entity may proceed with construction of the Mid-Span
Installation.
5. Make-Ready Electrical Construction. Where Make-Ready Electrical Construction is
required, the provisions of Section V.B.4 shall apply to a Mid-Span Installation.
6. Make-Ready Communication Construction – One Touch Transfers. If a proposed
Mid-Span Installation requires Make-Ready Communication Construction in the form of
one or more Simple Transfers, all provisions of Section V.B.5 shall be applicable.
7. Make-Ready Communication Construction - Complex Transfers. If a proposed Mid-
Span Installation requires Make-Ready Communication Construction in the form of one
or more Complex Transfers, all provisions of Section V.B.6 shall be applicable.
8. Notice of Attachment Completion and Acceptance. All provisions of Section V.B.7
providing for Notice of Attachment Completion and Acceptance shall be applicable to a
Mid-Span Installation.
9. Post-Construction Inspection. All provisions of Section V.B.8 providing for Post-
Construction Inspection shall be applicable to a Mid-Span Installation.
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SECTION VI.
SPECIFICATIONS FOR
BANNER ATTACHMENTS
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VI. SPECIFICATIONS FOR BANNER ATTACHMENTS
A. Banner Attachment Process
CPS Energy offers Banner Attachers access to Poles for the purpose of installing permanent
hardware components of a Banner Attachment to accommodate the display of a Double Pole
Banner. In addition, Banner Attachers may access Streetlight Poles to install permanent
hardware components of a Banner Attachment to accommodate the display of a Single Pole
Banner. Both of these permitted methods of attachment are subject to certain restrictions
and Make-Ready Work requirements pursuant to the Application processes outlined in
Figure G listed below.
The technical specifications for Banner Attachments are found in Appendix J. Additional
information, including the Application forms for a Banner Attachment, may be downloaded
at www.cpsenergy.com/poleattachments.
Figure G: Banner Attachment Application Process
Process Step
Standard
Process for
Banner
Attachments
Process
Criteria
Default Process
for Banner
Attachments
Make-Ready
Electrical
Engineering
(MREE)
CPS Energy
Application
Review Period30 Days
Make-Ready
Electrical
Construction
(MREC)
CPS Energy
Make-Ready
Banner
Attachment
Construction
(MRBAC):
1-Touch
Transfer-
Simple
Attaching Entity
MRBAC:
Complex-
Transfer
Attaching Entity
Post
Construction
Inspections
CPS Energy
Control over
Contractors
Attaching Entity
& CPS Energy
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B. Standard Application Process for Banner Attachments (Hardware)
A high-level workflow of the Banner Attacher Application review process for Banner
Attachments on CPS Energy Poles or Streetlight Poles subject to the use restrictions outlined
in Section VI.A, is illustrated in Figure H below.
1. Eligibility. Any Banner Attacher with a valid Banner Attachment Agreement.
2. Application for Permit Required. A Banner Attacher who qualifies for the Banner
Attacher application review process may choose either:
a) CPS Energy to Perform Make-Ready Engineering. Regarding Applications for
Banner Attachment, the Banner Attacher may request CPS Energy to undertake and
complete the Make-Ready Engineering required by the Application request. If the
Banner Attacher elects for CPS Energy to perform the Make-Ready Engineering,
CPS Energy shall provide the Banner Attacher an estimated cost to prepare and
complete the Make-Ready Engineering before starting the project. Upon approval to
proceed, CPS Energy will respond to such Application requests as promptly as is
reasonable, with a goal of providing a response within thirty (30) calendar days of
receipt of the Application. The Banner Attacher is still required to submit an
Application and pay all applicable Applications Fees as described in Appendix H.
CPS Energy will invoice the Banner Attacher for the cost to produce the Make-Ready
Work in accordance with the provisions of Section II.I.3; or
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b) Banner Attacher to Perform Make-Ready Engineering. The Banner Attacher may choose
to complete its own Make-Ready Engineering on an Application for Banner Attachment
by complying with all provisions of the Standard Process as described in Section IV.B
with the exception of Section IV.B.2.d.(i) Pole Loading Analysis (PLA).
c) Banner Attacher to Perform Make-Ready Engineering Design. Concerning Applications
for the Banner Attachment, the Banner Attacher will be required to file an Application
that includes engineering design drawings of the proposed Banner Attachment. The
Application shall identify:
(i) The Banner Attacher responsible for the installation of the Banner Attachment;
(ii) The Banner Attacher on whose behalf the Banner Attachment is being installed;
(iii) The owner of the hardware utilized to support the Banner Attachment and proof
of authorization to use the hardware;
(iv) The GIS coordinates of the Pole(s) or Streetlight Pole(s);
(v) The duration that the Banner Attachment will be on display;
(vi) Whether the Banner Attachment is a Single Pole Banner or Double Pole Banner
installation; and
(vii) A copy of the appropriate permit issued by the appropriate municipal
authority; along with other relevant information.
(viii) Applications for temporary display of Banner Attachments will be subject
to the Application Form provided in Exhibit H.
3. CPS Energy Review of Application.
a) CPS Energy to Perform Make-Ready Engineering. For Applications to install Banner
Attachment, if the Banner Attacher chooses to have CPS Energy complete the Make-
Ready Engineering pursuant to Section VI.B.2.a, then CPS Energy shall respond to
the Application within thirty (30) calendar days of receipt and provide the Banner
Attacher with a detailed description of the proposed Make-Ready Work required for
reasons of safety, reliability, or generally applicable engineering purposes.
b) Banner Attacher to Perform Make-Ready Engineering. If the Banner Attacher
chooses to be responsible for its own Make-Ready Engineering regarding an
Application to install hardware components of a Banner Attachment pursuant to
Section VI.B.2.a, then all provisions of Section IV.B.3 shall be applicable to CPS
Energy’s Review of Applications for Applications submitted by Banner Attacher.
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c) Review of Applications for Display of Banner Attachments on Existing, Permitted
Banner Attachment. CPS Energy shall endeavor to review and issue a Banner Permit
within seven (7) days. The Application review shall focus on receipt of a complete
Application to ensure that the Banner Attacher has obtained the appropriate
municipal authority for use of Public Right of Way and is compliant with contractual
and Standards requirements. A Banner Attacher may not use hardware or anchor
components of a Banner Attachment that belong to another Banner Attacher without
written authorization. Any Applications that propose to support a Single Pole Banner
or Double Pole Banner using hardware or anchors belonging to another Banner
Attacher without permission will be rejected.
d) Multiple Requests for Same Poles. Multiple requests to install Banner Attachments
in the same general area will be treated as follows:
(i) If CPS Energy issues a Permit, and the Banner Attacher fails to install the Banner
Attachment in compliance with Section VI, CPS Energy will release the requested
Pole or Streetlight Pole to another Attaching Entity that may have expressed an
interest in the affected pole structure.
(ii) Under no circumstances, will a Banner Attacher be allowed to reserve a Pole or
Streetlight Pole for future use.
4. Make-Ready Electrical Construction. All provisions of Section IV.B.4 shall be
applicable to Make-Ready Banner Construction for Applications considered under this
Section VI.
5. Make-Ready Banner Attachment Construction – One Touch Transfer. All
provisions of Section IV.B.5, including the use of NJUNS, shall be applicable to Make-
Ready Banner Construction for Applications considered under this Section VI.
6. Make-Ready Banner Attachment Construction - Complex Transfers. All provisions
of Section IV.B.6 shall be applicable to Notice of Attachment Completion and
Acceptance for Applications considered under this Section VI.
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7. Make-Ready Banner Attachment Construction - Complex Transfers. All
provisions of Section IV.B.6 shall be applicable to Notice of Attachment Completion
and Acceptance for Applications considered under this Section VI.
8. Post-Construction Inspection. All provisions of Section IV.B.8 shall be applicable to
Post Construction Inspection for Applications considered under this Section VI.
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SECTION VII.
APPENDICES
CPS Energy
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VII. APPENDICES
A. CPS Energy Attaching Entity Registration & Annual Reporting Form
B. CPS Energy Pole Attachment Program Forms
C. CPS Energy Notice of Dispute Form
D. CPS Energy Specifications for Attachments
E. CPS Energy Vertical Clearance Requirements
F. CPS Energy Attachment Clearance Requirements
G. CPS Energy Pole Loading Requirements
H. CPS Energy Schedule of Pole Attachment Rates, Fees, and Charges
I. CPS Energy Wireless Installation Diagrams
J. CPS Energy Banner Attachment Diagrams
K. CPS Energy Pole Attachment Tag List & Detail
L. Reserved for Future Use
M. CPS Energy Equal Employment & Anti-Harassment Policy
N. CPS Energy Information Systems Use Policy
O. CPS Energy Tree Trimming Specifications
CPS Energy
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Appendix A: CPS Energy Attaching Entity Registration &
Annual Reporting Form
CPS Energy
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CPS Energy
Pole Attachment Standards
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CPS Energy
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CPS Energy
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CPS Energy
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CPS Energy
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Appendix B: CPS Energy Pole Attachment Program Forms
B1: CPS Energy Application for Pole Attachment Permit
B2: CPS Energy Application for Wireless Installation Permit
B3: CPS Energy Application for Banner Attachment Hardware Permit and
Installation Notification
B4: CPS Energy Request for Pre-Certification of Wireless System
B5: CPS Energy Request for Waiver of Applicable Engineering Standards
B6: CPS Energy Authorization for Make-Ready Work
B7: CPS Energy Request for Temporary Attachment
B8: CPS Energy Completion of Attaching Entity Construction
B9: CPS Energy Notice to Proceed
B10: CPS Energy Permit for Attachment or Wireless Installation
B11: CPS Energy Permit for Banner Attachment Hardware Installation
B12: CPS Energy Notice of Unauthorized Attachment or Unauthorized
Wireless Installation
B13: CPS Energy Notice of Unauthorized Banner Attachment Hardware
Installation
B14: CPS Energy Pole Attachment Standards Revision Request (PASRR)
B15: CPS Energy Pole Attachment Standards Revision Request (PASRR)
Comment Form
B16: CPS Energy Notice of Safety Violation
B17: CPS Energy Notice of Safety Violation Assessment Charge
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B18: CPS Energy Notice to Remove Attachment(s) – Aesthetic or Civic
B19: CPS Energy Notice to Remove Attachment(s) – Customer Requested
Underground Relocation
B20: CPS Energy Notice to Remove Attachment(s) – Underground
Relocation
B21: CPS Energy Notice for Overtime Charges
B22: Notice of Acceptance for Overlash Application
CPS Energy
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B1: CPS Energy Application for Pole Attachment Permit
CPS Energy
Pole Attachment Standards
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B2: CPS Energy Application for Wireless Installation Permit
CPS Energy
Pole Attachment Standards
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B3: CPS Energy Application for Banner Attachment Hardware Permit and
Installation Notification
CPS Energy
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B4: CPS Energy Request for Pre-Certification of Wireless System
CPS Energy
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CPS Energy
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B5: CPS Energy Request for Waiver of Applicable
Engineering Standards
CPS Energy
Pole Attachment Standards
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B6: CPS Energy Authorization for Make-Ready Work
CPS Energy
Pole Attachment Standards
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B7: CPS Energy Request for Temporary Attachment
CPS Energy
Pole Attachment Standards
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Effective Date: January 1, 2019
B8: CPS Energy Completion of Attaching Entity Construction
CPS Energy
Pole Attachment Standards
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B9: CPS Energy Notice to Proceed
CPS Energy
Pole Attachment Standards
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Revision Date: December 06, 2018
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B10: CPS Energy Permit for Attachment or Wireless Installation
CPS Energy
Pole Attachment Standards
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B11: CPS Energy Permit for Banner Attachment Hardware Installation
CPS Energy
Pole Attachment Standards
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B12: CPS Energy Notice of Unauthorized Attachment or Unauthorized
Wireless Installation
CPS Energy
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Effective Date: January 1, 2019
B13: CPS Energy Notice of Unauthorized Banner Attachment
Hardware -Installation
CPS Energy
Pole Attachment Standards
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B14: CPS Energy Pole Attachment Standards Revision Request (PASRR)
CPS Energy
Pole Attachment Standards
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CPS Energy
Pole Attachment Standards
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B15: CPS Energy Pole Attachment Standards Revision Request (PASRR)
Comment Form
CPS Energy
Pole Attachment Standards
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Effective Date: January 1, 2019
B16: CPS Energy Notice of Safety Violation
CPS Energy
Pole Attachment Standards
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Revision Date: December 06, 2018
Effective Date: January 1, 2019
B17: CPS Energy Notice of Safety Violation Assessment Charge: CPS
Energy Notice of Safety Violation Assessment Charge
CPS Energy
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B18: Notice to Remove Attachment(s) (Aesthetic or Civic Projects)
CPS Energy
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Effective Date: January 1, 2019
B19: Notice to Remove Attachment(s) (Customer Requested Underground
Relocation)
CPS Energy
Pole Attachment Standards
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Effective Date: January 1, 2019
B20: Notice to Remove Attachment(s) (Underground Relocation)
CPS Energy
Pole Attachment Standards
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Revision Date: December 06, 2018
Effective Date: January 1, 2019
B21: Notice for Overtime Charges
CPS Energy
Pole Attachment Standards
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Revision Date: December 06, 2018
Effective Date: January 1, 2019
B22: Notice of Acceptance for Overlash Application
CPS Energy
Pole Attachment Standards
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Effective Date: January 1, 2019
B23: CPS Energy Notification for Micro Network Node Installation
CPS Energy
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Appendix C: CPS Energy Notice of Dispute Form
CPS Energy
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Appendix D: CPS Energy Specifications for Attachments, Wireless
Installations & Banner Attachments
The following engineering and construction specifications practices will be followed by the
Attaching Entity when making Attachments, Wireless Installations or Banner Attachments to CPS
Energy pole structures, as appropriate. The items listed below are not an exhaustive list, and are
intended to supplement, not replace the National Electrical Safety Code (NESC) or other
Applicable Engineering Standards required by the Pole Attachment Agreement, Wireless
Installation Agreement, Banner Attachment Agreement, CPS Energy Pole Attachment Standards,
or other applicable CPS Energy standards and specifications.
A. Wire Attachments:
1. Attachment and Cable Clearances: Attaching Entity’s Attachments on CPS Energy
Poles, including metal attachment clamps and bolts, metal cross-arm supports, bolts
and other equipment, must be attached so as to maintain the minimum separations
specified in the National Electrical Safety Code (NESC) and in the CPS Energy
drawings and standards provided in Appendix E and Appendix F. CPS Energy adopts
and requires Attaching Entity’s compliance with revisions of the NESC upon adoption
by NESC of those revisions. Compliance with NESC sections pertaining to overhead
communication lines will be stringently enforced by CPS Energy.
2. Sag and Mid-Span Clearances: Attaching Entity will leave proper sag in its lines and
cables and shall observe the established sag of power line conductors and other cables
so that minimum clearances are (a) achieved at Poles located on both ends of the span;
and (b) retained throughout the span. At mid-span, a minimum of four inches (4”) of
separation must be maintained between any other communication cables. At the Pole
support, a twelve inch (12”) spacing must be maintained between Attaching Entity’s
connection and any other Attaching Entities connection as noted in Appendix F.
3. Vertical Runs on Poles: All vertical runs on Poles, including those for power feed for
TV amplifiers, shall be placed on the quarter faces of the Pole and shall be covered by
a riser guard with a two-inch (2”) clearance in any direction from cable, bolts clamps,
metal supports and other equipment. The riser guard must not cover or obstruct any
CPS Energy identification tags on the pole. However, Attacher may request CPS
Energy to relocate the CPS Energy identification tags at the Attacher’s expense and
subject to CPS Energy sole discretion. Secondary cable providing service to Overhead
Streetlights may be covered with non-metallic conduit to allow minimum clearances to
communication cables as permitted in the NESC.
4. Cable Bonding: An Attaching Entity’s Messenger cable shall be bonded to the CPS
Energy Pole ground wire at each CPS Energy Pole that has a ground wire.
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5. Down Guys and Anchors:
a) Down guys shall not be bonded to ground or Neutral wires of the CPS Energy Pole
and shall not provide a current path to ground from the Pole ground or power system
Neutral.
b) All Attaching Entities shall provide their own anchors. Under no circumstances
is the Attaching Entity allowed to attach its guy to a CPS Energy anchor. Attaching
Entity’s anchors shall strive to be a minimum of four (4) feet from the CPS Energy
anchor.
c) No Attachments may be installed on a Pole until all required guys and anchors are
installed. No Attachment may be modified, added to, or relocated in such a way as
will materially increase the stress or loading on a Pole until all required guys and
anchors are installed.
d) Anchors and guys must be installed on each Pole where an angle or dead-end
occurs. Attaching Entity shall make guy attachments to Poles at or below the
height of its cable Attachment.
6. Service Drop Clearance: The parallel minimum separation between an Attaching
Entity’s Service Drops and telephone Service Drops shall be six inches (6”), and the
crossover separation between the drops shall be twelve inches (12”).
7. Omitted.
8. Service Clearances: A four-inch (4”) separation shall be maintained between CPS
Energy’s service cable and any other Attaching Entities facilities located on the
customer’s private property in accordance with the National Electric Code (NEC).
9. Climbing Space: All Attachments must be placed as to allow and maintain at all times,
a clear and proper climbing space on the face of the CPS Energy Pole. Cable
Attachments shall be placed on the same side of the Pole as existing telephone or
communication cables. In general, all other facilities and vertical runs should be placed
on Pole quarter faces.
10. Riser Installations: All Riser installations, including those providing 120/240 volt
power for Attaching Entity’s equipment enclosure shall be placed on the quarter faces
of a Pole and limited such that one side (180 degrees) of the pole is kept clear for
climbing space and future replacement of the pole and must be installed in CPS Energy
approved conduit with a weatherhead attached to the Pole with metal stand-off
brackets. Communication cable Risers shall be located on the same side of the pole as
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the overhead communication cables are attached and must not cover or obstruct any
CPS Energy pole identification tags on the pole. However, Attacher may request CPS
Energy to relocate the CPS Energy identification tags at the Attacher’s expense and
subject to CPS Energy sole discretion. Ground wires may be attached directly to the
Pole. There shall be forty (40”) inch separation from the top of an electric Riser to the
highest communication line.
11. Identification: All Attaching Entity’s Communication Facilities, including all cable,
shall be identified with Tags as required by these Standards and described in Appendix
K.
12. Telecommunication Cables: All telecommunication cables not owned by CPS
Energy shall be attached within the Communication Space that is located no less than
forty inches (40”) below the CPS Energy Neutral.
13. Communication Worker Safety Zone: The Communication Worker Safety Zone
between Communication Facilities and supply facilities on the same Pole extends
horizontally out to the boundaries of the climbing space and working space as described
in the NESC. The Communication Worker Safety Zone is measured vertically from
the level of the closest surface of the Communication Facility to the level of the closest
surface of the electrical supply facility. The required clearance of the Communication
Worker Safety Zone is measured vertically between the levels of the equipment
involved. Stand-off bracket installation will not be allowed to meet the forty inch (40”)
clearance requirement. No mounting brackets are permitted in the Communication
Worker Safety Zone.
14. Platforms: Communication Facilities/Attachments must dip underground one Pole
before and one Pole after on all CPS Energy Platforms for step-down and voltage-
regulator banks.
15. Power Supply: Attaching Entity shall install no power supply on any CPS Energy
Pole on which underground services, capacitor banks, sectionalizing equipment,
voltage-regulators, or other CPS Energy equipment is already installed.
16. Disconnect or Breaker. No electrical service connection to a communication power
supply shall be made or installed by Attaching Entity until CPS Energy shall have
completed an inspection of an approved fused service disconnect or circuit breaker
installed by the Attaching Entity.
17. Relocating Attachments: When moving an Attachment from one location to another,
Attaching Entity shall immediately treat all affected holes left in the Pole with industry-
acceptable wood preservative and plug all holes left by such Attachments.
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18. Bolts: No bolt used by Attaching Entity to attach its Communication Facilities shall
extend or project more than one inch (1”) beyond its nut.
19. Workmanship: Attaching Entity shall install and maintain any and all of its
Communication Facilities in a neat and workmanlike manner consistent with the
maintenance of the overall appearance of the Pole as determined by CPS Energy in its
sole discretion.
20. Attachment Arm: All Wireline Attachments shall be installed without the use of
Attachment Arms, extension arms, stand-off brackets or similar hardware, unless
otherwise approved in advance by CPS Energy for each Pole. The proposed use of
Attachment Arms, extension arms, stand-off brackets or similar hardware by an
Attaching Entity shall be identified on the Application for Permit.
21. Overhead Streetlight Clearances: Any Wireline Attachment proposing to attach
below the Overhead Streetlight fixture, shall be installed 12” minimum below the
bottom mast arm or drip loop of the Overhead Streetlight supply conductor whichever
is lowest. If proposing to attach 4” above the top mast arm,tThe Overhead Streetlight
supply conductor shall be covered with a non-metallic conduit. See Appendix F-1.
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B. Wireless Installations:
1. FCC OET Bulletin 65 (Maximum Permissible Exposure): A Wireless Provider
shall comply with all provisions and guidelines of the FCC OET Bulletin 65, as may
be amended from time to time. As part of the Pre-Certified Equipment process, and
prior to CPS Energy granting any Permit to attach, a Wireless Provider shall submit a
report certifying FCC OET 65 compliance for each applied or licensed Wireless
Installation location. The report can be in the format of the Wireless Provider’s
regulatory department standards. The following elements, at a minimum, must be
contained within the report:
a) A statement of compliance (or non-compliance),
b) Date of the report,
c) Date of statement of compliance,
d) CPS Energy Pole Number proposed for the Wireless Installation,
e) Attaching Entity’s site or identification number for the Wireless Installation,
f) GPS coordinates of the proposed pole for the Wireless Installation,
g) Calculation of RF power at the transmitter or Remote Radio Heads,
h) Calculation of RF power at the Antennas, and
i) Location of the applicable signage with above ground level height listed.
j) Wireless Equipment Specifications – Data Sheets for all Wireless Equipment that
make up the Wireless Installation setup. The data sheets shall include, at a
minimum, voltage requirements, ERP, EHF, licensed and unlicensed frequencies,
duty cycle, and FCC license reference copy. This information shall be organized
based on the four components of the Wireless Installation:
(i) Antennas, including brackets, cables, conduit, and enclosures.
(ii) Wireless Equipment Electronics, including Remote Radio Heads,
transmitters, transceivers, receivers, related electronic components,
communications cables, power supply wires, conduit, and enclosures.
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(iii) Backhaul Equipment, identify whether backhaul will be provided by wireless
antenna (including all applicable components) or by landline (fiber/other),
including the type of communications facility providing backhaul, name of
communications provider, conduit, and type of network interface device or
other component marking the point of demarcation with the communications
provider.
(iv) Power Supply, including the type of Service Disconnect Switch used to
shut off power and mark the point of delivery for electricity.
k) Wireless Interference Analysis Report
(i) The Wireless Provider must provide contact information for Wireless
Interference analysis follow up and for coordination when operational
circumstances require a power down of Wireless Equipment. Provide the
following contact information:
• Contact Name
• Contact Phone Number
• Contact Email
• Contact Company Name
• Contact Company Address
l) Interference Analysis – Report should include any calculated interference that
could be produced via interaction with CPS Energy licensed frequencies.
(i) C to I based study should be performed if carrier frequencies are adjacent or
co-channel to CPS Energy frequencies.
(ii) Study should list results in dB and can be done on service area basis.
m) Intermodulation Analysis – The Intermodulation Analysis Report (the “Report”)
must include a clearly written interference analysis of the Wireless Provider’s
licensed and unlicensed frequencies against the target frequencies provided by CPS
Energy.
(i) Assume minimum range of collocation to maximum range of source to be
two-thousand (2000’) feet.
(ii) If planned Wireless Equipment is to be within one mile of another FCC
licensed transmitter, the Report shall include those additional frequencies.
(iii) The Report shall also include any known interference that could be produced
via interaction with other FCC licensees in the referenced application band of
frequencies.
1. For the purpose of this item, assumed minimum range of collocation to
maximum range of source to be two-thousand (2000’).
2. Resulting report shall show non-interference against the target CPS
Energy frequencies to the seventh order.
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CPS Energy reserves the right not to accept Reports that CPS Energy in its
reasonable discretion deem incomplete, contradictory, and/or erroneous. All
statements of compliance must be signed by an authorized and responsible
employee of the Wireless Provider or the FCC licensee that owns the licensed
frequencies subject to compliance, if the Wireless Provider is not the same party
(the “Licensed Party”). The Wireless Provider or Licensed Party is required to
resubmit an annual Report and Statement of Compliance for each permitted
Wireless Installation location. The annual Report will be due on the anniversary
date for annual reports set by CPS Energy in Section II.F.
2. RF Signage Requirements. Approved signage compliant with FCC OET Bulletin 65
shall be posted at each Pole or Streetlight Pole hosting a Wireless Installation, and/or
at multiple locations on such pole structure as required by FCC OET 65. The RF
signage shall comply with the appropriate and predetermined exposure level applicable
to: “General Public”, “Occupational Worker”, and “Specialized Worker” as shown in
the figure below.
General Occupational Specialized
Public Worker Worker
All signage shall be 8” x 12” and made of weather, corrosion, and Ultra-Violet (UV)
resistant materials.
3. Antenna. All Antennas shall be located in a defined Antenna Area as provided in the
illustrations in Appendix I. The Antenna Area is not exclusive for the Wireless
Provider’s sole use, but shall be subject to CPS Energy’s use and operation of the Pole.
Antennas shall be bracketed onto the Poles or Streetlight Poles, excluding Pole Top
Antennas Poles.
a) Mid-Pole Antenna Type, Size and Quantity – Antennas can be of a panel or
omnidirectional type. Panel Antennas cannot exceed twelve inches (12”) in height
(vertical length), twelve inches (12”) in width, or eight inches (8”) in depth. Omni
directional antennas cannot exceed twelve inches (12”) in height (vertical length),
twelve inches (12”) in width (depth and with are the same measurement of an
omnidirectional antenna). There can only be one (1) antenna cylinder enclosure for
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a Mid-Pole Antenna installation. Additional consideration for Antenna height is
specified in Appendix I.
b) Pole-Top Antenna Type, Size and Quantity – Antennas can be of a panel or
omnidirectional type. Panel Antennas cannot exceed thirty six inches (36”) in
height (vertical length), twelve inches (12”) in width, or eight inches (8”) in depth.
Omni directional antennas cannot exceed thirty six inches (36”) in height (vertical
length), twelve inches (12”) in width (depth and with are the same measurement of
an omnidirectional antenna). There can only be three (3) antenna cylinder
enclosure for a Pole-Top Antenna installation. Additional consideration for
Antenna height is specified in Appendix I.
c) Licensed Frequency - Antennas shall only transmit or receive frequencies that
are licensed by the FCC to the Wireless Provider. No third party agreements are
accepted for non-licensed Wireless Providers to transmit or receive frequencies
of another FCC-licensed entity. Frequency bands listed by the FCC to be
unlicensed, and available for open use, may be transmitted or received, as long
as they do not cause interference with another Attaching Entity, FCC-license
entity, or CPS Energy.
d) Attachment Position and Defined Space
(i) Antenna clearances in any direction from supply and other
communications lines shall be in compliance with this Section B.3
(Antenna), Section B.11 (Mid-Span Installations), Section B.12 (Pole Top
Space Installations), B.13 (Mid-Pole Installations) and Appendix I. In no
circumstance shall an Antenna clearance be less than specified by the
NESC.13
(ii) A standoff bracket, supplement mounting pipe, and related hardware
cannot be greater than twelve inches (12”) in height (vertically) and six
inches (6”) in length (horizontally). Antenna Area cannot occupy more
than three (3) individual quarters of any pole’s cross-section. Additional
Antenna accessory equipment may be install within the limitations of the
defined Antenna Area. Antenna accessory equipment cannot interfere
with the operation or use of the applicable pole by other permitted
Attaching Entities or expressly CPS Energy. Antenna accessory
equipment can be affixed to the Attaching Entity’s standoff or Antennas.
All Antenna accessory equipment must be listed on the Application at the
time of submittal and included in any post-installation inventory.
13 Rule 235I, 2017 NESC, C2-2017.
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e) Emergency RF/ Power Shut-Off –CPS Energy shall open the Service
Disconnect Switch prior to performing any work on CPS Energy Pole in order
to de-energize the Antenna. Any backup power shall also be disconnected when
the Service Disconnect Switch is operated.
4. Riser Cable. Riser cables are used to connect Antennas and Antenna accessory
equipment, backhaul services, and power lines to Wireless Equipment components. All
Riser Cables shall be in conduit with top side weatherheads. Power cables transporting
AC power shall be in separate conduit from DC power or telecommunications cable.
All conduit shall be schedule 40 Rigid Steel Conduit (RSC) finished galvanized and
painted to match the Pole. All metallic conduit shall be bond to ground at the Antenna
Area ground point and at the Wireless Equipment area ground point.
a) Type, Size and Quantity - Cables can be coaxial, fiber optic, solid or stranded
metallic conductor. Hybrid cables, cable with two or more cable types enclose in
one sheath, are permitted. No exposed Riser cables, Riser cables not in conduit,
shall exceed the nominal size of 5/8 inch for coaxial or fiber optic, or 2 AWG for
solid or stranded metallic conductor.
b) Attachment Position and Defined Space - Riser cables must be affixed to the
structure with a two (2) hole pipe straps (minimum of 3 required to support the
service raceway).
No exposed Riser cable slack to be stored externally. All slack to be stored in
junction boxes or Wireless Equipment Cabinets within the Wireless Equipment
area.
5. Radio Equipment. Radio equipment can be located in RRHs, housed in the Wireless
Equipment Cabinet, or even within the Antenna itself. The most common application
of radio equipment is in the RRH. Radio equipment can transmit, receive, or
transceive.
a) Type, Size and Quantity - Radio equipment is not limited to size or quantity.
b) Attachment Position and Defined Space - Radio equipment shall be housed in the
Wireless Equipment Cabinet. An RRH shall not be mounted within the Antenna
Area or Pole Top Space.
6. Wireless Equipment Cabinets and Slab-Mounted Cabinet. A Wireless Equipment
Cabinet or Slab-Mounted Cabinet is a weathertight housing purposed to mount
components of the Wireless Installation. Typical devices housed in a Wireless
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Equipment Cabinet or Slab-Mounted Cabinet include: radio equipment, routers,
network interface devices, splice trays, computer electronics, DC power plants, power
inverters, circuit breakers, batteries, fans, heat exchangers, and assorted cable jumpers
interfaces. Wireless Installations shall be deployed based on the following two
installation designs:
a) Slab-Mounted Equipment Cabinet Installation. A Slab-Mounted Equipment
Cabinet installation is an available option installation design for Wireless
Installations, provided such installation does not create an obstruction in Public
Right of Way. A Slab-Mounted Equipment Cabinet must be at least twenty-five
feet (25’) from any CPS Energy pole structure, anchor, guy, conduit, or Riser as
shown in Appendix I, and must not exceed the dimension requirements in Chapter
284 of the Texas Local Government Code. Irrespective of statutory requirements,
CPS Energy encourages Wireless Providers to reduce the footprint of the Slab-
Mounted Equipment Cabinet. CPS Energy does not grant permission for Wireless
Equipment to be located on third-party property. It is the responsibility of the
Wireless Provider to secure legal authority to use such private property. Slab-
Mounted Equipment Cabinet installations must include provisions for CPS Energy
Meter and the Service Disconnect Switch. All such installations must comply with
CPS Energy Electric Service Standards and are subject to review and approval. For
Slab-Mounted Equipment Cabinet installation, the Antenna will be installed on a
CPS Energy pole structure.14
b) Wireless Equipment Cabinet Installation –A pole-mounted Wireless Equipment
Cabinet installation design is an available option for a Wireless Installation. All
Wireless Equipment shall be installed inside of the Wireless Equipment Cabinet for
all pole-mounted installations.
(i) Color and Dimensions – A Wireless Equipment Cabinet mounted on a
CPS Energy pole structure shall match as close as possible the color of
the pole structure. The maximum dimension for any Wireless Equipment
Cabinet shall (1) not exceed sixty inches (60”) in height, twenty-four (24”)
14 In instances where a provider intends to erect a “node support pole” pursuant to Chapter 284 of the Texas Local
Government Code, the provider must request electric service from CPS Energy. The provider shall (1) obtain an
address from the local jurisdiction; (2) provide CPS Energy the GIS coordinates for the node support pole; (3) install
a Slab-Mounted Equipment Cabinet or pole-mounted Wireless Equipment Cabinet; (4) install the node support pole
at least twenty-five feet (25’) from any CPS Energy pole, anchor, guy, conduit, or Riser; (5) install the antenna on the
node support pole a minimum distance of ten feet (10’) from CPS Energy’s neutral conductor and twenty feet (20’)
from any CPS Energy wireless antenna; and (6) otherwise comply with the requirements of Appendix I, Addendum
1. CPS Energy is adopting these specifications as Applicable Engineering Standards.
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in width, and twenty-four (24”) in depth.; and (2) must be bracketed to the
pole structure..
(ii) Weight of Equipment; Prohibited Poles - The total weight of any Wireless
Installation for a Wireless Equipment Area cannot exceed two-hundred
pounds (200 lbs). CPS Energy will review the required PLA in order to
approve the pole structure chosen prior to the installation of all new
Wireless Equipment Cabinet to confirm that the structure is suitable for
the installation. Wireless Equipment Cabinets may not be installed on:
1. Junction Poles (a Pole where the CPS Energy primary electric distribution
line runs in three or more directions);
2. Poles that are 60 feet or greater in size;
3. Transmission poles;
4. Poles with a Wireless Equipment Cabinet or Banner Attachment already
installed by another Attaching Entity;
5. Poles with cabinets containing controls such as fire alarm, police signal, or
traffic signals;
6. Poles with capacitor controls, regulator controls, recloser controls, air
switch operating handles, or an existing three-phase overhead transformer
bank;
7. Poles with single-phase transformers that are not accessible to mechanized
equipment (i.e., a bucket truck); and
8. Poles with underground electric or communication Riser conduits;
9. Poles not accessible to mechanized equipment (i.e., a bucket truck).
10. Pole structures used for guying purposes. and with no electric distribution
equipment or wires..
c) Markings – Wireless Providers shall install 8” x 12” signs or decals made of
weather, corrosion, and UV resistant materials easily visible from the ground level.
At a minimum, each sign or decal shall indicate the Antenna’s owner/operator’s
name, emergency 24-hour contact number, and unique identifier for that Antenna
site.
d) Wireless Equipment Installations - Installation of Wireless Equipment Cabinets and
Wireless Equipment Area for DAS Systems may be located outside the Public
Right of Way. CPS Energy does not grant permission for Wireless Installations to
be located on third-party property. It is the responsibility of the Attaching Entity
to secure legal authority to use such private property.
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7. Conduit Requirements. Conduits described in this section refer to below ground
conduits and transitions to Riser cable conduits or Wireless Equipment Cabinets.
a) Type, Size and Quantity - Below ground, all horizontal runs shall be schedule 40
PVC or SRD-11 HDPE. Transitions to above ground shall be in schedule 40 RGS
conduit with galvanized finish. All coupling points shall be threaded mechanical
or solvent-welded and watertight. Conduits cannot exceed a diameter of four inches
(4”). No more than four (4) conduits shall be permitted to affix to Wireless
Equipment Cabinets or Riser cable conduit.
b) Conduit Location - Conduits shall remain twelve inches (12”) from all other
Wireless Equipment below ground facilities. All conduits shall be locatable and the
responsibility of the Attaching Entity to locate per Texas law and the regulations of
the Damage Prevention Councils of Texas.
8. Backhaul Service. Backhaul service refers to the side of the network that
communicates with the core network and not between localized components of the
Wireless Installation installed on a pole structure. Backhaul service can either be
wireline or wireless.
a) Wireline Backhaul - Wireline backhaul service is typically fiber optic, as copper
circuits do not provide the necessary bandwidth for data throughput. Copper
telephone circuits and coaxial cables can as be use for wireline backhaul if
bandwidth speeds allow. All provision of Section IV and Section V of the
Standards apply to the installation of wireline backhaul services.
(i) Self-Provisioned - The Wireless Provider may provide its own backhaul
service if it has accepted a Pole Attachment Agreement and the
communications facility. The self-provisioned wire communications facility
may be existing or proposed. CPS Energy will make best efforts to review
both the wire Attachment Application and the Wireless Installation
Application concurrently. Applications and all associated documents must
have a common reference name for any concurrent Applications to be
considered as part of a common project.
(ii) Third-Party Provided - A Wireless Provider may contract backhaul service
from another Attaching Entity. The third-party provided wire
communications facility may be existing or proposed. If proposed, the third-
party Attaching Entity must have an executed Pole Attachment Agreement
and shall submit the Attachment Applications at the same time as the Wireless
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Installation Application is submitted. CPS Energy will make best efforts to
review both the third-party wire Attachment Application and the Wireless
Installation Application concurrently, but each Application shall be treated
separately for contractual purposes. Applications and all associated
documents must have a common reference name for any concurrent
Application to be considered as part of a common project.
(iii) Type of Backhaul Facility - Typically, the backhaul facility is a wire
Attachment on the same pole structure as the Wireless Installation.
Underground backhaul facilities are permitted when transitioning from any of
the following: (1) another CPS Energy Pole line; (2) a transportation crossing;
or (3) to an Attaching Entity installed pole. Applications with predominately
all underground backhaul services will not be approved.
(iv) Point of Demarcation – The Backhaul Network Interface Device is to be
clearly stated on the submitted engineering drawings, as required with the
Pre-Certified Equipment form and the Application, with the provider of
backhaul services clearly identified.
b) Wireless Backhaul - The Wireless Installation has the option to use wireless
backhaul services. Any Antenna for wireless backhaul services is counted towards
one (1) of the three (3) total cylinder antenna enclosures allowed on a pole structure.
Wireless backhaul service Antennas shall comply with all the specifications listed
in Appendix D, Section B.3.
(i) Type, Size and Quantity - All specification in Appendix D, Section B.3 shall
apply. In addition, wireless backhaul Antennas shall have the specific
azimuth (accurate to the degree) and the length of the link path (accurate to
the tenth of a mile) listed on the submitted drawings required by the
Application.
(ii) Attachment Position and Defined Space - All specifications in Appendix D,
Section B.3 shall apply.
(iii) Self-Provisioned - Self-Provisioned wireless backhaul services will be
approved by CPS Energy, consistent with the applicable provisions of the
Wireless Installation Agreement and these Standards.
(iv) Third-Party Provided - Third-party wireless backhaul services are prohibited
by CPS Energy.
(v) Point of Demarcation - Wireless backhaul services equipment shall be
installed pursuant to the technical requirements of Appendix I.
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9. Bonding. It is the policy and practice of CPS Energy to ground all Pole structures
installed as part of CPS Energy’s distribution system and streetlight service. Wireless
Providers are required to install their own specific ground electrode and ground bond
for their Wireless Installations. All of the following defined Wireless Equipment
components, or pole appurtenance listed, must be bonded: (1) Antenna(s), (2) Antenna
brackets (if applicable), (3) Riser conduit(s), (4) RRH(s), and (5) Wireless Equipment
Cabinets. There will be one central point of bonding at the Antenna Area and also at
the Wireless Equipment Area (pole or ground mounted). Central points of bonding
shall be a ground bar measuring no greater than, four inches (4”) high, twelve inches
(12”) wide, and exactly one-fourth inch (¼”) thick. Any two ground bars on a pole
structure. Pole must be connected via #2 AWG solid wire (aluminum, copper, copper-
clad aluminum, copper-clad steel) exothermically welded. All connections from
wireless components with factory-installed ground posts will be bonded with solid or
stranded wire mechanically (or hydraulically) crimp with lugs – the wire shall be
aluminum, copper-clad aluminum, copper, copper-clad steel and between #2 AWG to
#6 AWG in size. Lugs on the ground bar side will have two lug holes and two
mechanical fasteners. A fastener bolt nominal thread size (or factory grounding post)
for bonding shall be no smaller than one-sixteenth inch (1/16”) diameter than the lug
hole or ground bar hole. The closest ground bar to grade on any pole structure will be
bonded via #2 AWG solid wire exothermically welded to ground rod. Ground rods
shall be steel or copper-cad steel, 5/8-3/4 inches in diameter, and driven at least eight
feet (8’) below grade in undisturbed soil. All mechanical connections shall be “tool-
tight” with no play or slack if manipulated by hand. All metal material bonded must
be non-reactive to inhibit corrosion.
a) Existing Ground Present - An Application for any Wireless Installation shall note
if a CPS Energy ground is present or not at the specific pole structure location
proposed for the Wireless Installation. When an existing CPS Energy ground and/or
an Attaching Entity ground is present, the Wireless Installation ground bonding
electrode shall be bonded to existing ground rod(s) at a minimum of twelve inches
(12”) below grade. The ground wire size will be #2 AWG and exothermically
bonded on each ground rod. All Wireless Installation ground rods shall be at a
minimum twelve inches (12”) from other ground rods and/or anchors.
(i) No Sharing of CPS Energy Grounding Facilities - Wireless Installations shall
not bond to existing CPS Energy Facilities for grounding unless specifically
approved in writing by CPS Energy.
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b) No Ground Present – An Application for any Wireless Installation shall note if a CPS
Energy ground is present or not at the specific pole location proposed for the Wireless
Installation. If no ground is present, adding a CPS Energy ground may be an applicable task
for any CPS Energy approved Make-Ready Work.
10. Electric Service.
a) Equipment Subject to Electric Service - Wireless Equipment requiring electrical
service shall follow all applicable codes and regulations, including the National
Electric Code, as well as obtaining applicable local building and/or electrical
permits.
b) Compliance with CPS Energy’s Electric Service Standards – The Wireless Provider
shall comply with all applicable requirements provided in the CPS Energy Electric
Service Standards, as amended from time to time, for its Wireless Installation.
(i) Application for Electric Service – The Attaching Entity must make an
application for electrical service from CPS Energy as required by CPS Energy’s
Rules and Regulations Applying to Retail Electric and Gas Service, as may be
amended from time to time. The electric service application is not part of the
Application for the Wireless Installation Permit. Electric service applications
shall be received and processed by CPS Energy Customer Engineering not by
Pole Attachment Services. Completed application may be submitted by either
mail U.S. mail, electronically to [email protected], or other means mutually
agreeable by CPS Energy and the Wireless Provider.
(ii) Electric Metering – All electric services for Wireless Installations will be
metered. CPS Energy’s responsibility for the delivery of electricity to a
Wireless Installation ends at the “point of delivery” as that term is defined in
CPS Energy Electric Service Standards. The “point of delivery” for Wireless
Installations shall be as follows:
a) Slab-Mounted Equipment Cabinet - For Wireless Installations deployed
using the Slab-Mounted Equipment Cabinet design, the “point of delivery”
shall be at the line side of the meter socket located in the cabinet as provided
in CPS Energy’s Electric Service Standards.
b) Wireless Equipment Cabinet – For Wireless Installations deployed using the
pole-mounted Wireless Equipment Cabinet design, the “point of delivery”
shall be at the junction (service head) as provided in CPS Energy’s Electric
Service Standards.
c) Technical Drawings of Equipment Subject to Electric Service – Technical drawings
identifying all electrical specifications and requirements for the Wireless
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Installation shall be provided to CPS Energy as part of the Pre-Certified Equipment
process outlined in Section III.A.14, and should accompany every Application for
a Wireless Installation.
d) Backup Power – Backup power devices are not allowed.
11. Mid-Span Installations. All Mid-Span Installations shall be no closer than thirty-six
inches (36”) or no further than seventy-two inches (72”) from any CPS Energy Pole as
provided in Appendix I.
12. Pole Top Space Installations. Any Antenna installation in the Pole Top Space portion
of a CPS Energy pole structure must be on a wood or steel pole, and the engineering
and installation of such shall be part of the Make-Ready Work. All wood or steel pole
structures must be approved by CPS Energy. Pole Top Antenna Installations shall
comply with the following requirements:
a) Any Antenna in the Pole Top Space must not exceed twenty-four inches (36”) in
height (vertical length) and must meet the sixty inches (60”) clearance requirement
from the closest electrical conductor. All other specifications for an Antenna in
Appendix D shall apply. Additional specification and details for round-sectored
Antenna designs are provided in Appendix I.
b) U-Guard must be used to cover the cables which run from the Pole Top Antenna to
the Wireless Equipment Cabinet and must be installed opposite of “B” phase on the
pole structure.
c) CPS Energy shall install a ten foot (10’) cross arm on all Pole Top Antenna
installation designs.
13. Mid-Pole Installations. Any Antenna installation in the mid-pole portion of a CPS
Energy pole structure must be on a wood or steel pole, and the engineering and
installation of such shall be part of the Make-Ready Work. All wood or steel pole
structures must be approved by CPS Energy. Mid-pole antenna installations shall
comply with the following requirements:
a) Any Antenna in the mid-pole section of the pole must not exceed twelve inches
(12”) in height (vertical length), all other specifications for an Antenna in Appendix
D shall apply. Additional specification and details for round-sectored Antenna
designs are provided in Appendix I.
b) U-Guard must be used to cover the cables which run from the mid-pole Antenna to
a pole-mounted Wireless Equipment Cabinet.
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14. Mock-Up Installations. Prior to any submission of an Application for a Wireless
Installation, a Wireless Provider shall coordinate the mock-up installation of the
proposed Wireless Installation at CPS Energy’s training yard or any other location
designated by CPS Energy. The Wireless Provider shall schedule the mock-up
demonstration with the Pole Attachment Manager. The mock-up installation shall
be a realistic representation of how the Wireless Installation will be installed in
Public Right of Way. The following activities will be accomplished by a successful
mock-up installation:
a) Compliance with Applicable Engineering Standards – The mock-up installation
shall be constructed and inspected for compliance with all Applicable Engineering
Standards and Appendix I.
b) Safety Training – The mock-up installation will be used for “on site” and/or “in
class” safety training of CPS Energy employees regarding the specifications of the
Wireless Installation and any radio frequency occupational training related to
working in close proximity to the Antenna devices. This content shall be
incorporated into the Safety Briefing required by Section III.F.8. In addition, the
Wireless Provider installing a Pole Top Antenna must use an electrical contractor
approved by CPS Energy to perform all work in the Electrical Space on the Pole.
c) Meter Installation – The mock-up display may include the installation of a Slab-
Mounted Equipment Cabinet installation, or a pole-mounted Wireless Equipment
Cabinet installation, both of which shall include a Meter and Service Disconnect
Switch connected to the Wireless Installation in compliance with CPS Energy’s
Electric Service Standards.
d) Pole Use Measurement – Once CPS Energy certifies that the mock-up installation
is fully compliant with all the requirements of Appendix D, Section B, CPS Energy
will measure and document the number of feet that the Wireless Installation covers
on the Pole. This measurement will be used for the purpose of determining the
annual Wireless Installation Fee for all Wireless Installations of the same
configuration.
e) Approval of Pre-Certification of Wireless Equipment Form – Upon completion of
the pre-certification process, CPS Energy will approve the Pre-Certification of
Wireless Equipment Form which will authorize the Wireless Provider to begin
submitting Applications for the same pre-certified Wireless Installation
configuration. Should the Wireless Provider at any time wish to upgrade Wireless
Equipment that will substantially change the pre-certified Wireless Installation
configuration, or deploy new Wireless Equipment technology under a different
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Wireless Installation configuration, the Wireless Provider shall coordinate a new
mock-up installation to pre-certify the alternative Wireless Installation
configuration. CPS Energy will not accept Applications for an alternative Wireless
Installation configuration that has not been pre-certified.
15. CPS Energy Work on a Pole. CPS Energy shall de-energize Wireless Equipment
prior to performing any work on a pole structure with twenty-four (24) hour without
prior notice to the Wireless Provider at the NOC. Such advance notice may be
provided by telephone or email.
C. Banner Attachments:
Banner Attacher shall comply with the following engineering and construction practices
when making Banner Attachments on Poles or Streetlight Poles as applicable:
1. General Clearances. Maintain the minimum separations and clearances specified in
the NESC or CPS Energy whichever is more stringent applies.
2. Double Pole Banner Clearance. Concerning Double Pole Banners maintain
minimum clearances at Poles located on both ends of the span and retain minimum
clearances throughout the span. At mid-span, a minimum of 12 inches of separation
must be maintained from any other cables. At the Pole support, a 12-inch separation
must be maintained between Banner Attachment pole-mounted hardware and any other
facilities on the Pole.
3. Clearances from CPS Energy Facilities and Other Attachments. Banner
Attachments are not allowed within forty inches (40”) below CPS Energy Neutral and
must maintain a twelve inches (12") minimum separation from any wire Attachments.
4. Grounding. Concerning Double Pole Banners, bond metallic support cable to the Pole
ground wire at each Pole that has a ground wire.
5. Climbing Space on Pole. Maintain a clear vertical movement climbing space,
ascending and descending, on the sides of the Poles that are parallel with the street.
6. Double Pole Banner Dimensions. A Double Pole Banner spanning a street shall be
no more than thirty-six feet (36’) in length, four feet (4’) in height, and not more than
one hundred forty-four square feet (1442’) total area.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 55
Revision Date: December 06, 2018
Effective Date: January 1, 2019
7. Banner Material. Double Pole Banners spanning the street or road shall be
constructed of net or mesh material to significantly decrease wind loading. Single Pole
Banners shall be constructed of light weight, non-toxic material in accordance with
City of San Antonio requirements. Double Pole Banners shall not be constructed of
plastic or vinyl.
8. Single Pole Banner Brackets. Single Pole Banner brackets installed on Underground
Streetlight Poles shall be painted the same color as the Underground Streetlight Poles.
Banner Attacher is responsible for maintenance of the brackets.
9. Banner Clearance from Ground. Double Pole Banners shall maintain a minimum
clearance of eighteen feet (18’) to the street grade Single Pole Banners shall maintain
a minimum clearance of twelve feet (12’) to sidewalk or existing grade behind curb.
10. Single Pole Banner Dimensions. Two Single Pole Banners are permissible on a single
Pole, provided they are located on opposite sides of the pole structure and the sum of
the combined area of both Banner does not exceed 2,128 square inches.
11. Banner Bracket Design. Single Pole Banner Brackets shall be static banner hardware
design type to minimize wind resistance.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 56
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix E: CPS Energy Vertical Clearance Table
Clearance Adders: The vertical clearances required by the NESC are the absolute minimum
clearance allowed by CPS Energy in order to issue a Permit. To ensure that NESC clearances are
met under all reasonably anticipated circumstances, CPS Energy may require additional tolerances
for movement and variances in construction to be added to the NESC requirements. The clearance
values in this section include CPS Energy adders, unless otherwise noted.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 57
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix F: CPS Energy Attachment Clearance Requirements
30”
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 58
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix F-1: CPS Energy Attachment Clearance Requirement
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 59
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix G: CPS Energy Pole Loading Requirements
It is the determination of CPS Energy that pole attachments can have a significant wind loading
and stress effect on a pole and can cause overloading. Therefore, nothing should be attached to a
pole that is not engineered to be there in advance.
1. Engineering and Planning Qualifications: Any Pole Loading Analysis (PLA)
submitted as part of the Application package shall be signed and sealed by a licensed
Professional Engineer approved by CPS Energy.
2. PLA Submittal Requirements: Attaching Entity shall submit PDF copies of the full
PLA report for each pole identified as requiring a PLA study pursuant to this Appendix
G. Acceptable software for use of PLA will be a commercially available product with
general industry acceptance. Should the Attaching Entity utilize a software application
that CPS Energy does not possess, Attaching Entity shall make available to CPS Energy
at least one software license for CPS Energy use at Attaching Entity’s expense.
3. Pole Loading Parameters: PLA is to be performed in accordance with the
requirements of Light Loading Zone as described the current version of the National
Electric Safety Code (NESC)15 for the San Antonio area. CPS Energy PLA Grade
Requirements shall be as follows:
• Single Circuit: NESC Grade C unless required to be Grade B by the current version
of the NESC.
• Double Circuit: NESC Grade C unless required to be Grade B by the current
version of the NESC. CPS Energy may require Grade B design at “critical” double
circuit areas, as identified by CPS Energy.
• Wireless Installations: NESC Grade B is required for any Pole or Overhead
Streetlight Pole utilized for a pole-mounted equipment cabinet Wireless
Installation.
4. Required Conditions for PLA: CPS Energy will require PLA for the following
conditions:
• Poles with angles of greater than 10 (guyed & un-guyed) - single & double circuit
• Poles with primary spans greater than 200 feet
• All un-guyed poles with “break-offs”
o 3 phase primary breakoffs only
• All CPS Energy dead-end poles
• All Poles with CPS Energy 2 & 3 transformer banks, reclosers, and capacitor banks
• All Poles less than Class 3 for which 3-phase electric distribution is installed
15 NESC Rule 250, Figure 250-1, C2-2017
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 60
Revision Date: December 06, 2018
Effective Date: January 1, 2019
• All Poles with five (5) or more Attachments, other than Mid-Span Installations, and
primary, secondary and Neutral attachments
• All Poles for which a Wireless Installation or Mid-Span Installation is requested.
For Mid-Span Installations, both end-point Poles shall have a PLA completed.
• Any critical Pole identified by CPS Energy not specified in categories above, up to
ten percent (10%) of total Poles per Application
• If Overlashing and wireline Attachments exceeds a combined total of three and one-
half inches (3.5”) in diameter
5. Reserved Capacity for Proposed Pole Change Outs: CPS Energy shall require
Reserved Capacity for any new or replaced Pole as follows:
• Single Circuit: five percent (5%)
• Double Circuit: fifteen percent (15%)
• Hollow composite Pole: fifteen percent (15%)
6. Pole Loading Analysis Time Limitations: PLA analysis shall be valid for a time
period of no longer than six (6) months from the time of Application submission. After
this six (6) month period, a new PLA analysis will be required.
7. Exceptions to PLA Requirements: CPS Energy will not require PLA for the
following conditions:
• When Overlashing a 144-strand or smaller diameter and weight fiber optic or other
cable
• When placing a fiber optic cable in an existing aerial inner duct
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 61
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix H: CPS Energy Schedule of Pole Attachment
Rates, Fees, and Charges
Although CPS Energy is exempt from the definition of the term “utility” that applies to the
regulations of the Federal Communications Commission (FCC) relating to pole attachments made
by providers of telecommunications and cable services; CPS Energy uses the current FCC formula
applicable to providers of telecommunications services. CPS Energy reserves the right to adjust
this Schedule of Pole Attachment Rates, Fees, and Charges in accordance with any changes in the
FCC formula delineated below, and with updated CPS Energy cost information. The Application
Fee does not cover back office engineering services and field inspection work provided by CPS
Energy or its contractor’s part of the Application review process.
1. Application Fee
a) Wire Attachments. There is no Application Fee for a Wire Attachment.16
b) Wireless Installations. There is no Application Fee for a Wireline Attachment.
c) Banner Attachment Hardware. For Banner Attachment Hardware, the Application
Fee shall be $50.00 per pole-mounted installation.
2. Annual Fees
There is no Application Fee for notices.
a) Wire Attachments. The Attachment Connection Fee is the annual rental payment
assessed by CPS Energy to each Attaching Entity with wire Attachments. The
annual Attachment Connection Fee is determined by CPS Energy for each
Attaching Entity by multiplying [Attachment Rate] x [total number of Permitted
Attachments for the Attaching Entity].
(i) Overlashing an existing Permitted Attachment is not a separate Attachment
and will not be subject to a separate Attachment Connection Fee.
(i)(ii) A Mid-Span Installation utilizing the same one foot of Communication Space
as the Messenger cable to which it is attached in accordance with Applicable
Engineering Standards is not subject to the Attachment Connection Fee,
provided that the annual Attachment Connection Fee is billed to the
Messenger cable.
(ii)(iii) The applicable Attachment Rate formula, the annual Attachment Rate, and
the financial and operational inputs utilized by CPS Energy’s in the
calculation of the Attachment Rate formula are available on the CPS Energy
public webpage at www.cpsenergy.com/poleattachments.
16 As noted in Section II.I.2, CPS Energy will discontinue the $8.77 Application Fee for wire Attachments effective
January 1, 2017.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 62
Revision Date: December 06, 2018
Effective Date: January 1, 2019
(iii)(iv) CPS Energy will use the Attachment Rate formula as required by law.
b) Wireless Installation Hardware. The Wireless Installation Fee is the annual rental
payment assessed by CPS Energy to each Attaching Entity with Wireless
Installations. The annual Wireless Installation Fee is determined by CPS Energy
for each Attaching Entity by multiplying [Wireless Rate] x [total number of pole-
feet per Wireless Installation] x [total number of permitted Wireless Installations
owned by the Attaching Entity].
(i) The Wireless Rate shall equal the Attachment Rate.
(ii) A Mid-Span Installations shall only be assessed the Attachment Connection
Fee for the amount of Attachment space outside the one foot of
Communications Space as the Messenger Cable to which the Mid-Span
Installation is attached as required to comply with the vertical clearance
requirements of the Applicable Engineering Standards on the both Poles on
either side ofclosest to the Mid-Span Installation and at the mid-span
(ii)(iii) Application of Annual Fee to Mid-Span Installation,. A Mid-Span
Installation shall not be subject to a Wireless Installation Fee, but may be
subject to an Attachment Connection Fee, if it does not utilize only the same
one foot of Communications Space as the Messenger cable to which it is
attached in accordance with Applicable Engineering Standards or the
Messenger cable to which it is attached is not billed the annual Attachment
Connection Fee.
c) Banner Attachment Hardware. The Banner Attachment Connection Fee is the
annual rental payment assessed by CPS Energy to each Banner Attacher with
Banner Attachment hardware. The annual Attachment Connection Fee is
determined by CPS Energy for each Banner Attacher by multiplying [Banner
Attachment Rate] x [Total number of permitted Attachments] x [Total number of
pole feet reserve by the Banner Attachment hardware to display Banners].
3. Unauthorized Attachment Charge and Unauthorized Banner Attachment Charge
An Attaching Entity shall pay CPS Energy, in addition to the annual Attachment
Connection Fees or Banner Attachment Connection Fees that would have been payable
for such Attachments if they had been authorized, an Unauthorized Attachment Charge
as provided below:
a) For entities without a valid Pole Attachment Agreement or Banner Attachment
Agreement, the Unauthorized Attachment Charge or Unauthorized Banner
Attachment Charge shall be $500 per year for each Unauthorized Attachment or
Unauthorized Banner Attachment.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 63
Revision Date: December 06, 2018
Effective Date: January 1, 2019
b) For Attaching Entities with a valid Pole Attachment Agreement or Banner
Attachment Agreement, the Unauthorized Attachment Charge or Unauthorized
Banner Attachment Charge shall be five (5) times the annual Attachment
Connection Fee (in effect at the time the Unauthorized Attachment or Unauthorized
Banner Attachment is discovered) per Pole per year if the Attaching Entity does not
have a Permit and the violation is self-reported or discovered through a joint
inspection; with an additional sanction of $100 per Pole per year if the violation is
found by CPS Energy during any inspection or during Inventory in which the
Attaching Entity has declined to participate.
c) If the date on which the Unauthorized Attachment or Unauthorized Banner
Attachment was made cannot be determined, the Unauthorized Attachment or
Unauthorized Banner Attachment will be assumed to have been installed by the
Attaching Entity on the next day following the last completed Inventory, not to
exceed five (5) years.
4. Unauthorized Wireless Installation Charge
An Attaching Entity shall pay CPS Energy, in addition to the annual Wireless
Installation Fees that would have been payable for such Wireless Installations if they
had been authorized, an Unauthorized Wireless Installation Charge as provided below:
a) For entities without a valid Wireless Installation Agreement, the Unauthorized
Wireless Installation Charge shall be $500 per month for each Unauthorized
Wireless Installation.
b) For Attaching Entities with a valid Wireless Installation Agreement, the
Unauthorized Wireless Installation Charge shall be $100 per month per Wireless
Installation where CPS Energy has not issued a duly authorized Permit for the
Wireless Installation to the Attaching Entity.
c) If the date on which the Unauthorized Wireless Installation was made cannot be
determined, the Unauthorized Wireless Installation will be assumed to have been
installed by the Attaching Entity on the next day following the last completed
Inventory, not to exceed five (5) years.
5. Other
a) Non-Compliance with Complex Transfer Process
Pursuant to Section IV.B.6 of the CPS Energy Pole Attachment Standards, CPS
Energy shall levy a penalty of $350 per non-compliant Attachment to the Attaching
Entity failing to make the Complex Transfer in the required timeframe.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 64
Revision Date: December 06, 2018
Effective Date: January 1, 2019
b) Non-Compliance with Joint Meeting Transfer
Pursuant to Section IV.B.5 of the CPS Energy Pole Attachment Standards, CPS
Energy shall levy a penalty of $350 per day to the non-compliant Wireless Provider
that fails to attend and/or fails to complete the transfer or modification of a Wireless
Installation within the required Joint Meeting Transfer ten (10) day timeframe. The
penalty shall become automatically effective on the eleventh (11) day following the
Joint Meeting Transfer.
c) Safety Violation Assessment Charge
The Safety Violation Assessment Charge is $500 per Safety Violation identified.
d) Tracing Line Ownership Fee
In the event any Attachment, Wireless Installation, or Banner Attachment is
untagged and CPS Energy must determine the owner’s identity to address the repair
or maintenance of a CPS Energy Pole, equipment, or facility that CPS Energy
cannot undertake absent removal or transfer of said Attachment, Wireless
Installation, or Banner Attachment; CPS Energy shall bill the owner of the
Attachment, Wireless Installation, or Banner Attachment for time reasonably
undertaken by CPS Energy to determine the identity of the owner of the
Attachments, Wireless Installation, or Banner Attachment. The Attaching Entity
that owns the untagged Attachment, Wireless Installation, or Banner Attachment
shall pay CPS Energy the Tracing Line Ownership Fee of $150.00 for the first hour
plus $100.00 per hour thereafter. Partial hours shall be rounded up. CPS Energy
shall bill the Attaching Entity within thirty (30) days of determining the Attaching
Entity’s identity.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 65
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix I: CPS Energy Wireless Installation Diagrams
I1: CPS Energy Wireless Antenna Installation – Mid-Pole - Slab Mounted
Equipment Cabinet
I2: CPS Energy Wireless Antenna Installation – Mid-span -Slab Mounted
Equipment Cabinet
I3: CPS Energy Wireless Antenna Installation - Pole Top Space (Round-
Sectored) - Slab Mounted Equipment Cabinet
I4 CPS Energy Antenna Installation – Pole Top Space (Round-Sectored)
with Mid Pole Wireless Backhaul Antenna - Slab Mounted Equipment
Cabinet
I5: CPS Energy Wireless Antenna Installation - Overhead Fed Streetlight
Pole -Slab Mounted Equipment Cabinet
I6: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight
Pole with Mid Pole Wireless Backhaul Antenna – Slab Mounted
Equipment Cabinet
I7: CPS Energy Wireless Antenna Installation – Mid-Pole – Pole Mounted
Equipment Cabinet
I8: CPS Energy Wireless Antenna Installation – Pole Top Space (Panel)
I9: CPS Energy Wireless Antenna Installation – Pole-Top Space (Round-
Sectored) – Pole Mounted Equipment Cabinet
I10: CPS Energy Wireless Antenna Installation – Pole Top Space (Round-
Sectored) with Mid Pole Wireless Backhaul Antenna – Pole Mounted
Equipment Cabinet
I11: CPS Energy Wireless Antenna Installation – Pole Top Space (Combo)
– Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 66
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I12: CPS Energy Wireless Antenna Installation - Overhead Fed Streetlight
Pole - Pole Mounted Equipment Cabinet
I13: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight
Pole with Mid Pole Wireless Backhaul Antenna– Pole Mounted
Equipment Cabinet
I14: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight
Pole – Pole Top Space (Panel)
I15: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight
Pole – Pole Top Space (ComboPanel) – Pole Mounted Equipment
Cabinet
I17: Addendum 1: CPS Energy’s Technical Design Standard for Node
Support Pole (Electric Service Request) – Slab Mounted Equipment
Cabinet
I17: Addendum 2: CPS Energy’s Technical Design Standard for Node
Support Pole (Electric Service Request) - Pole Mounted Equipment
Cabinet
I18: Addendum 3: CPS Energy’s Wireless Technical Design Standard for
Node Support Pole (Electric Service Request) – Customer Owned Steel
Pole with Concrete Foundation – Pole Mounted Equipment
I19: Addendum 4: CPS Energy’s Wireless Technical Design Standard for
Node Support Pole (Electric Service Request) Installation – Customer
Owned Pole – Pole Mounted Equipment Cabinet
I20: Addendum 5: CPS Energy’s Wireless Technical Design Standard for
Node Support Pole (Electric Service Request) – Customer Owned Steel
Pole with Concrete Foundation – Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 67
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 68
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I1: CPS Energy Wireless Antenna Installation – Mid-Pole- Slab Mounted
Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 69
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I2: CPS Energy Wireless Antenna Installation – Mid-Span–Slab Mounted
Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 70
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I3: CPS Energy Wireless Antenna Installation – Pole Top Space (Round-
Sectored) – Slab Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 71
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I4: CPS Energy Wireless Antenna Installation – Pole Top Space (Round-
Sectored) with Mid-Pole Wireless Backhaul Antenna – Slab Mounted Equipment
Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 72
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I5: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight Pole –
Slab Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 73
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I6: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight Pole
with Mid Pole Wireless Backhaul Antenna – Slab Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 74
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I7: CPS Energy Wireless Antenna Installation – Mid Pole – Pole Mounted
Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 75
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I8: CPS Energy Wireless Antenna Installation – Pole Top Space (Panel)
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 76
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I9: CPS Energy Wireless Antenna Installation – Pole Top Space (Round-
Sectored) Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 77
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I10: CPS Energy Wireless Antenna Installation – Pole Top Space (Round
Sectored) with Mid Pole Wireless Backhaul Antenna Pole Mounted
Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 78
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I11: CPS Energy Wireless Antenna Installation – Pole Top Space
(Combo) – Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 79
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I12: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight
Pole - Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 80
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I13: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight
Pole with Wireless Backhaul Antenna - Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 81
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I14: CPS Energy Wireless Antenna Installation – Overhead Fed Streetlight
Pole – Pole Top Space (Panel)
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 82
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I15: CPS Energy Wireless Antenna Installation – Overhead Fed
Streetlight Pole – Pole Top Space (Combo) – Pole Mounted
Equipment Cabinet (Panel)
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 83
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I16: Addendum 1: CPS Energy’s Technical Design Standard for Node Support
Pole (Electric Service Request) Slab Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 84
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I17: Addendum 2: CPS Energy’s Technical Design Standard for Node Support
Pole (Electric Service Request) Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 85
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I18: Addendum 3: CPS Energy’s Wireless Technical Design Standard for
Node Support Pole (Electric Service Request) – Customer Owned
Steel Pole with Concrete Foundation – Pole Mounted Equipment
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 86
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I19: Addendum 4: CPS Energy’s Wireless Technical Design Standard for
Node Support Pole (Electric Service Request) Installation – Customer
Owned Pole – Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 87
Revision Date: December 06, 2018
Effective Date: January 1, 2019
I20: Addendum 5: CPS Energy’s Wireless Technical Design Standard for
Node Support Pole (Electric Service Request) – Customer Owned Steel
Pole with Concrete Foundation – Pole Mounted Equipment Cabinet
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 88
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix J: CPS Energy Banner Attachment Diagrams
J1: CPS Energy Typical Banner Attachment – Single Pole
J2: CPS Energy Typical Banner Attachment – Double Pole
J3: CPS Energy Typical Banner Attachment – Single Underground
Streetlight Pole
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 89
Revision Date: December 06, 2018
Effective Date: January 1, 2019
J1: CPS Energy Typical Banner Attachment – Single Pole
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 90
Revision Date: December 06, 2018
Effective Date: January 1, 2019
J2: CPS Energy Typical Banner Attachment – Double Pole
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 91
Revision Date: December 06, 2018
Effective Date: January 1, 2019
J3: CPS Energy Typical Banner Attachment – Single Underground
Streetlight Pole
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 92
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix K: CPS Energy Pole Attachment List & Detail
K1: Pole Attachment Tag List as of AprilAugust 31, 20197
1 CPS Energy 34 American Tower Corp.
2 Charter
35 Beledon Roofing Company
3 AT&T/SBC 36 Ancira Winton Chevrolet, Inc
4 Grande Communication
37 Texas A&M University
5 MCI-Verizon
38 Weatherford Artificial Lift
6 COSA Traffic 39 Schlumberger Technology
6 COSA TCI 40 NextEra FiberNet
7 AT&T Long Distance 41 Zayo Group, L.L.C
8 Time Warner Telecom
42 APOGEE
9 TPX Communications 43 Windstream KDL, INC
10 GVTC 44 University Health System
11 GVCS
45 Witte Museum
12 Fort Sam Houston 46 Conterra
13 Carrell Communications
47 Google Fiber Texas, L.L.C
14 Rapid Communication 48 ExteNet Systems, Inc
15 VIA Metropolitan Transit
49 Mobilitie, LLC-Sprint
16 Verizon GTE
50 AT&T – Nexius
17 Alpheus Communication
51 Dixie Flags
18 Holt Texas LTD dba Holt CAT
52 Lone Star Media
19 Martin Marietta Materials 53 Unite Private Networks
20 University of Incarnate Word 54 Verizon Wireless
21 Somerset I.S.D
22 TCG(Houston) AT&T Local
23 Leon Valley
24 SAWS
25 Time Warner Telecom
26 Zachry Constr. Corp.
27 Southwest I.S.D
28 Northeast I.S.D
29 Qwest Communications
30 Fiberlight L.L.C.
31 New Path Networks, LLC.
32 Level 3 Communications, L.L.C.
33 Schertz-Cibolo-Universal City ISD
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 93
Revision Date: December 06, 2018
Effective Date: January 1, 2019
K2: Pole Attachment Tag Detail
For the purposes of Tagging an Attachment, Overlash or Wireless Installation (including a Mid-
Span Installation), CPS Energy requires the use of a Tag placed within twelve inches (12”) of a
Pole on the wires and cables, coded by number, color, or other means that will readily identify the
owner of the Attachment at a Pole from ground level. The Tag shall be as specified below or
consistent with accepted communication industry standards or other Attaching Entity supplied tag
approved in writing by CPS Energy, provided the Tag is made of materials which are weather,
corrosion, and Ultraviolet (UV) resistant.
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 94
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix L: Reserved for Future Use
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 95
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix M: CPS Energy Equal Employment Opportunity
and Anti-Harassment Policy
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 96
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 97
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 98
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 99
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix N: CPS Energy Information Systems Use Policy
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 100
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 101
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 102
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 103
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 104
Revision Date: December 06, 2018
Effective Date: January 1, 2019
Appendix O: CPS Energy Tree Trimming Specifications
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 105
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 106
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 107
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 108
Revision Date: December 06, 2018
Effective Date: January 1, 2019
CPS Energy
Pole Attachment Standards
Revision: 4.0 Page: Appendix - 109
Revision Date: December 06, 2018
Effective Date: January 1, 2019